hodgman, mha on september 15'' 2017, during a 45 … › ctee › council...wastewater...
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Legislative Council Sessional Committee Government Administration ASub-Committee
Fin Fish Farming in Tasmamia Inquiry
Submission from Geoffrey Swan, Lonnavate Tasmania
Terms of Reference:
I ) The implementation of the Sustainable industry Growth Plan for the Salmon Industry and itsimpact on commercial finfish farming operations and local communities, including:
a. data collection and publication
2) Application of the Marine Farming Planning Act 1995 relating to:
b. management of finfish farming operations with respect to the prevention ofenvironmental harm
Dear Sir or Madam
Please find enclosed my submission to this inquiry which is specific to theoperation of the Huon Aquaculture Company Hatchery situated alongside theRussell River in Lonnavale, Tasmania.
This submission is the result of some 10 plus years of research, collation ofevidence and personal observations from our property some 2.2km downstreamfrom the hatchery and along the stretch of the Russell River. Parts 2 and 3 of thissubmission are updated excerpts from a Dossier provided to the Hon. Premier WillHodgman, MHA on September 15'' 2017, during a 45 minute board room meeting,at which time our Premier said to me "we will fix this issue. .. it has been ongoingfor too long and is sounding like groundhog day".
With the exception of the River Catchment study which had been mooted some 12months earlier, nothing else has come out of that meeting to this day, now some2+ years on.
The downstream pollution of the Russell River continues to be a direct result ofthe activities of the Huon Aquaculture Company, as has finally been confirmed inthe River Catchment study. All other possible sources of pollution to this river toinclude agriculture, forestry, human activities, the nearby Rivers Edge Campingground and any possible leaking septic systems have all be categoricalty discountedthrough the proper analysis of data which was primarily supplied by HACthemselves.
Our Premier was presented with eight actions which could assist in the ongoingpollution of the Russell River, but not one of the suggestions actions have beenundertaken by our Government. I will present these actions once again in the hopeour Government will at least consider what has been a very longstanding issue ofenvironmental pollution to a once pristine mountain stream.
Fin Fish Inquiry submission from Geoffrey Swan age I
GAA/FIN 46
Aquaculture Hatcheries in Tasmania
As at August 2017 (H508382_RTioz8) there were 17 such hatcheries throughoutTasmania with five of those a combination of flow through and recirculationsystems, and the remaining 12 being flow through only. I am only reliant onanecdotal evidence for some of the other hatcheries, but I am advised there areissues arising from waste discharges into the downstream sections of the oncepristine freshwater rivers similar to that of the Lonnavale facility.
A flow through system uses fresh water diverted from the flowing river which isdirected into tanks or ponds containing brood fish. This oxygen rich pristine waterin turn circulates through the tanks and in so doing picks up fish faeces and anyundigested feed, and is then discharged downstream of the Intake point. Theremay be a drum filter intercepting the flow to filter the solids; however there areindustry questions around the effectiveness of such filters as solids are broken intoeven small particles and the high nutrient still enters the waterway, causingdownstream eutrophication in the form of filamentous green algae.
A recircutation aquaculture system (RAS) is a self-contained system where thewater is treated (most often including ozone) and is then returned into the system.Solids are collected and often removed off site. Waste water is often stored in
settlement ponds and in due course irrigated onto nearby pasture or land.
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Fish Inquiry submission from Geoffrey Swan
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Huon Aquaculture Company Hatchery, Lonnavale
This hatchery has both flow through and RAS systems in operation. in 2015 the GMof HAC Freshwater advised it would cost $1m to convert the flow through systemto a RAS system; "money we do not have" he said.
The enclosed part 2 of this submission provides an overview of the history of thisfacility and highlights the ongoing issue of downstream eutrophication to theRussell River which has been ongoing in excess of 12 years, The Huon ValleyCouncil, followed by the EPA served EPN's on HAC over the years to measure thenutrient outputs from the flow through system into the river.
There are also EPN's served on HAC for the RAS system but these relate to mattersof water treatment, storage and removal, and have not until recently consideredthe impact of possible run off from their irrigation of the RAS waste water onto thenearby clay soils and tree plantation.
As a result of an independent "Catchment Nutrient Study for the Russell River atLonnavale", commissioned by the EPA and provided by Dr Rebecca Ketty, publishedin October 2018, the EPA have become aware of nutrient discharge flowing backinto the river as a result of the RAS irrigation system.
This waste water has not been captured in the testing undertaken in the past 10+years and is now a matter being explored by HAC and the EPA with a plan for June2020.
The KetIy report (along with subsequent inspections of any possible leaking septicsin the area by the Huon Valley Council), has now conclusiveIv confirmed thedownstream eutro hication and jin acts on the Russell River are solel fromthe respective waste water discharges from the HAC Hatchery.
On August 28'' 2019, Director Environment Protection Authority, Wes Ford wrote tome in part:
"In regard to ongoing regulation of the Lonnavate fish farm, EPA's position is thatthe conditions of the current Environmental Licence are appropriate to manage theenvironmental risks of the activity. The conditions require a revision of theWastewater Reuse Environmental Management Plan to be submitted in June 2020.Huon Aquaculture have begun preparation of that plan. "
Fin Fish inquiry submission from Geoffrey Swan age 3
a. data collection and publication
Data is collected by the industry themselves, in this case the Huon AquacultureCompany. This data is provided to the EPA as part of their EPN. There is anecdotalevidence pertaining to their hatchery in Lonnavale and their Hatchery in Ranelagh,that persons taking samples have been known to sample upstream of the dischargepoints.
There is evidence the EPA have on occasion provided prior notice of a planned visitwhen the EPA will undergo some random testing.
Director EPA, Wes Ford has advised that in order for the EPA to engage acontractor, to in turn invoice (in this case) HAC, and to subsequently provide testresults to the EPA and to HAC, this would require legislative change.
There have even been concerns raised in the community about the independenceof the State testing laboratories with suggestions an interstate laboratory shouldbe engaged. This does not sound respectful for our Tasmanian Laboratories, butperhaps in the interests of complete transparency a random set of tests could beundertaken with an interstate laboratory to ease any concerns of collusion orinfluence.
Unfortunately this industry has done itself no favours in terms of honesty andtransparency, and it is timely to put in place systems that are beyond reproach inorder to gain community confidence.
b. management of finfish farming operations with respect to theprevention of environmental harm
The bulk of this submission relates to the environmental harm being caused to theRussell River by the practices of the Huon Aquaculture Company facility inLonnavate. There is without question simply based on the visual and photographicevidence there is environmental nuisance occurring downstream of the facilityalmost all year round.
During heavy rains the eutrophication is often cleared, but rapidly returns within amatter of week(s) and sometimes days. The sensitivity to nutrient levels forphosphorous in particular and nitrogen are such that a very small increase willtrigger instantaneous algal growth.
There have also been suggestions made by HAC that evidence of increasedmacroinvertebrate activity is a sign of a healthy downstream river. This is amisnomer.
There is strong anecdotal evidence of a decreased amount of trout being evidentdownstream as against upstream. This is further illustrated by the higher count ofmacroinvertebrate species downstream. Macroinvertebrates are the food for trout
Fish Inquiry submission from Geoffrey Swan age 4
and by "hiding" within the increased algal growth they are not eaten by trout andtrout simply migrate to cleaner waters where food is readily accessible.
It is my strongly considered view after 10+ years of study and engagement with ourauthorities that the management of this particular hatchery is seriously lacking.The agreement by former Directors EPA, IFS, Ministers and indeed the Premier thatthere is an ongoing issue is a very poor reflection on any action actually beingtaken. The amount of action taken to enforce the prevention of the ongoingpollution of the Russell River by the Huon Aquaculture Company is indeed atrave sty and if there were far more people impacted it would not be as it is today.
As a lone voice, with the exception of support from Mr Richard Dax, a long timefisherman, and a long time advocate for this river, the battle has indeed been ofDavid and Goliath proportions.
Prime concern with the status quo
Finally there is an understanding and an acceptance by the EPA that the source ofthe downstream pollution of the once pristine mountain stream is as a direct resultof the activities undertaken by the Huon Aquaculture Hatchery in Lonnavale.
At first Huon Aquaculture rejected the findings of the Ketty Report and called ontheir own independent water scientist, Dr Lois Koehnken to review the report.
It will now be a further 18 months delay before yet another report is undertaken toexplore the issue of the run off irrigation water which is deemed to be impactingthe Russell River.
Question
Dr Rebecca Ke!Iy has confirmed the river water upstream from the HAC facility ispristine mountain water, or as close to pristine as can be for a river. Downstreamfrom the facility the river suffers year round eutrophication consisting offilamentous green algae, a year round slippery river bed with brown algae and hasdiminished trout compared to upstream.
The nutrients levels are high in phosphorous and nitrogen, and suspended solidscompared with upstream, and yet the Director EPA, Wes Ford is stating the level ofdownstream pollution is at an acceptabte level.
By what acceptable measure can any person or authority suggest there is a level of"acceptabte" pollution in our waterways. A community river that serves a numberof residents downstream as household water and livestock water.
How is it possible, and why is it acceptabte, that one business is allowed to impactan important water source through the pottuting activities of their business.
Fin Fish inquiry submission from Geoffrey Swan age 5
The Huon Aquaculture Company purports to be the torchbearer of quality salmonproducers and the protector of the environment within which they operate.
Firstty let them now demonstrate this by the closure of their "no longer consideredbest practice" flow through systems and to now integrate these into their twomajor recircutation plants; one that is already on site in Lonnavale and their latestfacility at Forest Home in Judbury.
Secondly, why is our community once again forced to wait for yet another reportthat is a further 18 months awayin the knowledge the hatchery is the cause of thedownstream pollution.
This is simply about one small mountain stream which industry has been allowed tosystematically degrade with the blessing of the Authorities responsible and in thefull knowledge of Peter and Frances Bender.
This is simply not acceptabte but no one appears concerned.
Further reference to the plight of the Russell is available at:
htt ://WWW. tasconservation. or .au/tas-conservationist/2016/12/19/de radation-of-the-russell-river-an-an Iers-o inion
Fin Fish Inquiry submission from Geoffrey Swan age 6
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The Huon Aquaculture Fish Farm on the Russell River, Lonnavale, TASMANIA
The enclosed documentation represents an amassing of some 10 plus years of evidence of deceit,oofuscation, and the ongoing dereliction of duty of our Tasmanian regulatory authorities to take anydemonstrative action to prevent the downstream devastation of the Russell River; due to the dailypolluting activities of the Huon Aquaculture Company Hatchery (HAC).
Two former Directors EPA - Jones and Schaap, current Director EPA - Ford, current Director IFS - Diggte,Acting Director EPA - Mollison, Professor Peter Davies and Minister Groom have all accepted andacknowledge that the downstream eutrophication of the Russell is substantially due to, if not wholly dueto, the daily discharges of high nutrient fish farm effluent into the river from the HAC fish farm.
Despite years of unquestionabte evidence, an extensive collection of monthly and annual photographs,extensive coverage in the media (ABC, Mercury, Huon News and Tasmanian Times) and years ofcommunication and written correspondence with all possible authorities, the discharges from theHatchery into the Russell continue uriabated. When comparing downstream 2009 with downstream 2019there is more often than not, little to no noticeable visible improvement, despite three EPN's, threescientific reports and the "pub test" fact that there has never been anv visible algae recorded upstreamof the Lonnavate fish farm.
NO , P. TI A ND BU
The independent "Catchment Nutrient Study for the Russell River at Lonnavate", commissioned by theEPA and provided by Dr Rebecca KetIy was published in October 2018. Finally there is confirmationthat the downstream eutrophication of the Russell River is due to the outputs of the HuonAquaculture Fish Farm, with the only unaccounted for possibility being any local leaking septicsystems.
A TI C MO N ST
The Huon Valley Council confirmed to me 26'' June 2019 they have since inspected all local systems andthere are no leaking septic issues.
htt s:/ /e a. tas. ov. au/Documents/AssessmentOf Nutrientsources RussellRiver FINAL Hi hRes 20190102. of
The cause of the ongoing eutrophication and destruction of the Russell River is unequivocally aresult of a Hatchery that was established without any environmental requirements, without anyrequirement of a Development Application and without any consideration of any other users of thisonce pristine community river. This is a tragedy still in progress to this day.
THE CREATION OF A POLITICAL AND BUREAUCRATIC MONSTER
The Huon Aquaculture Fish Farm on the Russell River, Lonnavate, TASMANIA
ORIGIN
o Originally established in 1996 - 2006 as a small family Trouthatchery business using outdoor handmade clay ponds and flowthough fresh water redirected through a handmade channel fromthe Russell River. All waste was discharged into the Russell River.
o By all accounts taken over in 2006 by Peter and Frances Bender.
o No planning or environmental considerations were required or wereput in place by the Huon Valley Council on the basis of it beingexisting agricultural land use.
o IFS issued a 10 year Fish Farm Licence to Huon AquacultureCompany (HAC) commencing September 1st 2007 - August 31st 2017.(Renewed by IFS September 2017 for a further 12 months with no change to the conditions)
o Immediate construction of what is today a multimil!ion dollarfacility consisting of the original flow through fish farm clay pondsystem, and a new undercover recirculating aquaculture system.
o Instead of hundreds of Trout in the flow through ponds, HAC filledthe five c!a onds with 49 tonnes of Salmon and the downstream
impact of this dramatic action was immediately evident.
o Recent RTl information has now revealed HAC placed in excess of45 tonnes of Salmon into the outdoor ponds from 2005 onward. Thiswas two Years prior to having the necessary Fish Farm Licence.
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EARLY IMPACTS OF THE FISH FARM
o Throughout 2007 the Russell River downstream was completelycovered in filamentous long green algae up to 10km and moredownstream to the confluence of the Huon River.
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o Local residents, Anglers Alliance Tasmania Inc. and the TasmanianFarmers and Graziers Association all responded to the dramaticallychanged River situation and sought assistance from both the HuonValley Council and the Benders themselves.
o Intense media focus at the time along with road blockades and amassive Community unrest ensued.
o Benders remained resolute their fish farm was not the issue and
suggested all sorts of obscure reasons for the downstream algae.
However, no visible algae has ever been recorded__ to this da
upstream of the fish farm discharge pipe despite claims by Bendersand the Environment Protection Authority to the contrary; toinclude a spurious letter from the Bender's housekeeper - GayBranch. (Letter written August 10,2010 - just days before Peter Bender provided WarrenJones with Davies 2009 Report which clearly indicated the cause was the Fish Farm)
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HUON VALLEY COUNCIL ACTIONS
. Following involvement from the HVC; in December 2007 the Bendersremoved all but 30 - 40 brood fish from their five flow through clayponds; however the river had perhaps irrevocab!y changed and stillthe filamentous long green algae proliferated downstream.
(in 2017 HAC were maintaining up to 6000 brood fish - 6 tonnes in their outdoor clay ponds)
o in March 2007 the HVC served HAC with an Environment Protection
Notice EPN 2007/ I ; followed soon after by an Infringement Noticeand a fine.
o Wrong river classification of lowland river when it is an uplandstream - meaning wrong nutrient limits and the wrongunderstanding of the rivers capacity to accept the high nutrienteffluent discharge.
o DPIPWE Water Resources advised the water flows in the Russell are
insufficient to accommodate flow through - HAC permitted to takeup to 90% of the total river flow.
o IFS Director Diggte expressed concern about increasing State widecomplaints arising from point sources such as fish farms.
o Resident complaints continued and ultimately got the attention andconcern of DPIPWE Environment - then Director Warren Jones.
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ENTER THE ENVIRONMENT PROTECTION AGENCY
o February 2008 and DpiPWE Environment seeking to take overregulation of the facility and propose to serve a new and moreappropriate EPN with revised limits.
o EPA advise Senate Estimates March 2008 that an EPN is imminent
but nothing ha. .ens for 6+ Years,
o Neither HVC nor the EPA take any more action until6 years and 6months later - internal (RTl) emails reveal neither HAC nor EPAcould work out how to remedy the issue - it was all guess work.
o EPA finally serve HAC with EPN 7667/1 in October 2014.
o Limits set in concert with HAC who supplied the EPA with thenutrient data needed to sustain a flow through hatchery,meantime still guessing on feed limits and stocking.
o Supposed decreasing nutrient limits over a three year period putin place in EPN 7667/2 and served in February 2015.
o EPA Technical Report January 2016 then increases limits to an"enforceab!e" limit which is higher than previous limits,
therefore providing HAC with increased nutrient latitude.
o Director EPA Ford (and earlier EPA advice) advises downstreamat at cover is because of 10n er da Ii ht hours, the warmer waterand low river flows.
o In June 2017 the downstream algal cover was as bad as it wasback in November 2009 - a cold 10'C, shortest day of the yearand the river was high flowing.
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o Director EPA Ford then advises algae can also occur in these coldwater conditions, with limited sunlight and increased flow,
o Inquiries to EPA and DPIPWE Water Resources confirm HAC arepermitted to take 0.3Cumecs per day (26 million litres) of waterfrom the Russell.
o EPA confirm that at times of the year the entire flow of theRussell is 0.3Cumecs per day - therefore HAC have a licence toextract I 00% Of the River. (Locals recall Frances Bender boasting about this fact)
o Water Resources are not concerned with the water take because
they consider it to be "non consumptive". Actual water "quality"is of no concern to Water Resources. (Martin Read DpiPWE)
Investigations at the water intake reveal there is no flowmetering in place for water being diverted into the facility.
o The intake channel into the HAC fish farm has had inoperablegates and controls over the flow well before Benders took over.
No operable gates in the in^ake channelI '
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, Pipes^into channel - no gates or controls
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o The flow meter at Lorkins Bridge is situated in an annual pool ofwater - therefore is not reliable for measuring river flow.
o All testing of the River sampling is undertaken by HAC staff withinformation then provided to the EPA. This is not independentmonitoring and is Open to abuse. (Anecdotal evidence confirms this)
o EPA do undertake very occasional random sampling and adviseHAC when they will be testing. (Revealed in emails in RTi documents).
o Director EPA Ford advised legislation prohibits the EPA engagingan independent company to undertake sampling and theninvoicing HAC for the Service. (Advised in a meeting April 27,2017).
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ACKNOWLEDGEME T FISH FARM Is THE CAUSE
o All four EPA Directors (Jones, Schaap, Acting Mollison and Ford)confirmed in writing that HAC are the cause of downstreameutro hication that must be resolved sooner rather than later.
o Davies 2009 Report was commissioned and paid for by HAC andkept Commercial in Confidence. (Finally accessed by swan following 4 yearswith RTl and eventually the Ombudsman in July 2017)
o Re ort confirms HAC knew it was their problem in 2008/2009.
o November 2009 Swan family informed by the EPA, HVC, HAC andDavies that HAC were not the cause of the rotific downstream
algal growth. (November 9,2009 on site meeting Russell River)
o Acknowledgement that flow through is "not best practice" byDirector IFS Diggle (July 2014), Minister Groom (october 2016), andDirector EPA Ford (August 20th.
o Director EPA Ford states he is accepting a level of pollutionimpact from HAC but is not seeking zero impact on the RussetRiver (October 2015).
o Davies 2009 Report advises another River study should beundertaken in I - 3 years' However a follow up Report is notundertaken until 2015 some 6 Years later - were the EPA asleepon their watch.
o August 28th 2017 Director EPA Ford refused to release any of thetest results or macroinvertebrate studies undertaken on the
Russell since 2008 - referring us yet again to the RTl process.
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FLAWS AND CONCERNS IN THE ARGUMENT
HAC and EPA continue the rhetoric there are other nutrient
inputs into the river - this is patentty false. They continue torefer to how much better the River is now compared to 2007when they had 49 tonnes of fish present in the ponds, when theComplaints first Surfaced. (HAc and EPA gave this exact sameinformation to theHVC management in May 2017)
o There was never an at at issue in the Russell when Forestry andAgriculture in Lonnava!e was at its peak.
o HAC suggesting duck and platypus faeces are the cause of thealgae (HAC Annual Environmental Management Review March 2017) and marsupialfaeces (May 2017). Why therefore is there no algae upstream?
o Erroneous comments in Davies 2009 and 2105 Reports. Erroneousand misguided information in the HAC March 2017 AnnualEnvironmental Management Review. Still speculation aboutpossible extraneous inputs and causes of algae.
o Flow meter placement issues and the locations of sample testing.
o Sampling, testing and reporting is by HAC staff - it is notindependent. Arm's length company structure but still anemployee of HAC. (Doin o'Brien)
o Despite all the testing, despite all the EPN's and limits, anddespite the supposed changes to feed limits and stocking limits,the situation downstream has not improved since 2008. (Following
the mass uplift of the 49 tonnes of fish).
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ANNECDOTAL EVIDENCE
(Hearsay advice from people who will not come forward through fear of retribution andtheir connection to employment and the Benders)
o HAC knowingty take water samples at the wrong locations to thatrequired in the EPN - often upstream and at times when theirimpacts on the river may be reduced.
o HAC discharge large volumes of high nutrient water from theirrecircutating system into the Russell when the river is in highflow and when cleaning their tanks. (Evidenced on one occasion with a largemass of white foaming water and another occasion with EPA testing confirming plasticiserswere in the water, and strong chemical odours in the downstream river)
o HAC do use antibiotics and hormones in their Fish Farms despitepublicly suggesting otherwise.
o HAC are advised well in advance when the EPA is visiting and/orplanning any EPA based testing.
. Facility was closed for 4 months in 2017 and the downstreamriver (over summer) was the best seen in 9 years' Within 4 weeksof resumed activity the downstream algal cover returned with aVengeance. (Also evidenced by decreased vehicle movement to the fish farm - staffvehicles, feed trucks, waste trucks, tankers - all having to pass Swan's property)
o The entire facility may be a factor in the downstreameutrophication with the run off from their upland irrigation alsoimpacting the Russell together with leakage issues.
o Recreational angling catch rates are low below the hatcherywhilst above the rates are similar to those prior to 2006.
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WHAT ACTIONS I ASKED OF PREMIER HODGMAN
SEPTEMBER 15'' 2017 - To NO EFFECT
Direct the EPA to force the Huon Aquaculture Company to closedown their antiquated and no longer best practice clay flowthrough ponds - why:
o Because there has been I O years of downstreameutrophication and never any observed or recorded upstream
o Because there is an ongoing environmental nuisance
Occurring, (that should be enforced butts not) if not harm
o Because despite all efforts since 2007 by the HVC and the EPAnothing downstream has changed
o Because the nutrient limits are not correct for a cobbled
stream and following site specific ANZECC requirements andneed to be adjusted down (Director EPA Ford has advised if the limitsare any less they will need to close down the flow through system)
o Because five Directors (EPA a IFS) have all agreed this hasbeen ongoing for too long and it is n0 10n er best ractice
o Because they have proven (Forest Home) that they cansupport their brood fish in a closed RAS system with apparentzero impact to the environment
o Because Director EPA Ford said to us in April27,2017 "If theHuon the Aquaculture Company or the Snowy Range Hatchery(Little Denison River) were applying for a similar licence in2017 - thev would be refused"
Z. Ensure ongoing testing continues in our freshwater rivers (HAC intheir March 2017 Annual Environmental Management Reviewsuggested it was no longer necessary to undertake testing and awaste of time and money). Director Ford has accepted thatposition, for now, but it must not be considered appropriate atany time going forward.
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3. Bring about the legislative change (as advised by Director Ford)to allow the EPA to engage truly independent businesses toundertake the routine sampling and testing. These businesses tothen invoice the polluters (HAC in this case) and then provide thereports to the company, the EPA and the public. (More jobs)
4. Instigate regular truly random testing by the independent testingbusinesses with no prior warnings to the polluters.
5. Move the ineffective flow meter in the Russell River (near Lorkinsbridge which is 24/7 in a large pond of water) to a better realflow location. These results to be managed and recorded byDPIPWE Water Resources and not HAC staff.
6. If HAC are to continue being allowed to take water from theRussell then working intake control gates and flow and volumemeasurement systems must be installed and monitoredbyDPIPWE.
7. Immediately, (during the process of closing down) reduce thenutrient limits in the EPN down from enforceable to the lowest
possible limit to meet site s ecific ANZECC guidelines.
There are no other nutrient inputs into the 3km stretch of the
Russell other than the HAC fish farm. There may well be nutrientrun off from their upland irrigation - but we will not know thisfor sure until the flow throu h s stem is full closed down.
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UPDATE: The Russell River Catchment Study was completed inOctober 2018 and published in February 2019.
The study has proven conclusivety that the downstreameutrophication of the Russell River is BECAUSE of the operationsat the Huon Aquaculture Hatchery in Lonnavale.
it is NOT because of local agriculture, forestry practices, thenearby Rivers Edge Camping group or any other possible inputsother than the fish farm.
Leaking septics was the only other possible impact, even thoughmodelling and water samples proved this was/is not possible.However, at my request, the Huon Valley Council have sincechecked all the local septic systems and have confirmed thereare no leakages or issues which would be impacting the river.
From the test results undertaken by HAC for the EPA, it has beenpossible to isolate the source of the downstream pollutioncoming from the fish farm.
The outcome is that the most probable cause is from irrigationrun off water from the RAS system which is systematicallyirrigated up into the nearby plantation.
As at March 2019 there are new investigations underway into thispolluting source with a view to assess this issue. However, theEPA is allowing HAC to review this for a further 15 months with areport due June 2020.
This 10+ year issue has been allowed to go on and on with theblessing of our environmental guardian, and with no respect forthe other users of this once pristine community river.
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SELECT PHOTOGRAPHIC EVIDENCE
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EPA advise this#i's normal h Tasmanian Ri ers
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Downs ream o. ber 2009
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SELECT PHOTOGRAPHIC EVIDENCE
ay 27,2010 . . ell RiverI
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SELECT PHOTOGRAPHIC EVIDENCE
September 4,2014 downstream Russellg. River
Septe ber 4,2014 downstream Russell River
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SELECT PHOTOGRAPHIC EVIDENCE
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The General ^lingerHuon Valley CouncilMain Rd. , HuonvilleTAS 71 09
^,'aqo/,
12th Novanber 2007To whom it may concern,1<0r 1' '~ ,.
After receiving advice from solicitors (a copy of which is enclosed), and then talking toHeIona Bobby on 1/11/07, we wish to write a formal complaint regardin the state of the
I ' er and to ress concerns for the h tii and recreation of funil and 'ends.
We, and others, on many occasions have complained to councilors in regard to theappalling state of the Russel River and have not received any satisfactory response in atime period that we believe acceptsble, from council or councilors.On approaching the Council, the advice has been to boil the water. We would like toblow Council's view on whether boiling the water will reduce chemical and/'or antibioticsubstances which we've been led to believe are being used in the hatcheries.in the summer of 2006/2007 the river was a disgrace in regards to algae, long strands ofgreen weed, and brown slime covering the rocks, making it dangerous to impossible touse the river for SIvirrm, ing or other recreational activities. This problem remained righttillougl, our the following winter as there was substantially reduced rainfall. it is also amajor concern as the river has always been the source of drinking water
, , which we are no longer able to use and are now forcedto buy drinking water ;
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RECORDSFile NG! ...<?.^"Q7^^'."
N0:.!;^;;!71!.(I. .,^:;^'.. IConcerned residents
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Copy of ti, . 'ompleteoriginal record
Prior to the last 2 years we have found it a great\
privilege to have use of such fresh clean, rinh, ERl water, to drinlc, bathe in and enjoyfishing slyirmnirig, e. Lc. , but unfortunately this is no longer the case.it has also been brought to attention the Stock Vendor Declaration foms, required whenstock is sold, specifically chin : I. Have any of tile stock in this consignnerit ever in theirlives been treated with a hornonal growth promotant (HGP)?
2. in the past 60 days have any of these stock been fedby- product stock feeds?
3.1n the past 6 months have any of these stock been on aproperty listed on the ERP database or placed under restrictions because of chemicalresidue?
As this is a statutory declaration we are concerned that we may be providing f^iseinfonnation as we are urice^in if these additives are present in the fish food (^^ellets)which inadvertently end up in the river and are passed onto stock through drinkinginstead of fomging. If this were proven to be the case it could daringe not only 100al butnational meat export to certain countries where these stringent conditions apply.We to believe, fineugli observation, that the source of contamination in the river is aconsequence of the fish fomi on the Russel River at Loiniavale.On many occasions we have been to the swimnin hole on the property which is directlopposite one of the effluent entry illts of which we've observed 4 or more emueiit
it^, t adminin hole wasjilts d^tl into the river. 2 ears o thisen
ni'DEP, ,Rin^91'700 ' '' not a coin, ,,,
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in colour anddeep containing c stal clear water but now is op ue, cloudunusable also dangerous for swirlunir, g and diving in for the childre as the bottom ofthe river bed cannot be seen.
The closer to the fish fom you get the more abundant the gi'een strands of slime andbrown slime covering the rocks become. We have also noticed a few new plants in theriver which could possibly be introduced exotic weeds and could spread and become athreat to the native vegetation. Another observation we've made comes from standingnear the bridge just upstream from the fish farm. Upstream the water is crystal clear andthe rocks have very little slime coverage, whereas downstream a few metres only, theslime is thick and water condition very poor. This water upstream from the bridge is inthe same pristine condition as that of which we have been very privileged to have hadaccess to, in the entire river, prior to this project gaining momentum.We find it hard to believe at this time when clean water is such a valuable resource and
there is so much controversy in the country at present about clean water, the lack of it,and water conservation and pollution control, that such a project is able to proceedwithout having stringent guidelines to follow which prevent it from causing hall, , to theenvironment, potential health implications or nuisance to others,We also find this sinetion an hypocrisy as Council initiated, tlunugli it's own PEV's,large amounts of rate payers funds to , properties on theRussel River to fignce off and prevent contamination to this precious resource by stock, toenhance the pristine condition of this river, which is a tributary to the Huon catchmentsand Huon drinking water supply.This problem also has financial implications for the substantial investinent we have inthis region as the propedy has, up until this project, enjoyed a much privileged prerntumon real^state resale due to the proximity to clear clean water.We are not anposed to fish fanning, but we are of a strong view that water taken out ofthe river should be of the same pristine condition it was originally in when it is put backinto the river. if these conditions aminot be achieved we believe the farm should be
closed down until they can be achieved, or relocated to an area where a nuisance to othersis not an issue.
Enclosed is a list of concerned residents.
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DEP, RinfEN7, 73'@"drhe ENP//?0 \;R I e ENP//?0 \;11EV7
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Fax: 6261 8051
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War^I. toms am^tag. cov. au
12/11/2007,115AM
John,
To Jofin. 01991e@its. as. gov. auDayid. Mitchell@envlronmenLtas. gov. au
Step, Ien. [email protected] Lonrnvala Fish hatctrery
d
Please see the note below from one of my officers,
its been a while since I have personally dealt with a fish hatchery - as you n^y be aware theyare not Level2 activities that we regulate. However, my recollection from days gone by isthat hatcheries must be licensed by 113S. I am pretty sure that some of these licenses have hadreference to some basic environmental management requirements.
Can you pis advise whether you licence this facility and whether there are any conditionsrelating to environmental management in it Do you have any 10.0wledge of the issues that areraised by the complainant?
I am aware that the Council has issued an EPN in relation to the hatchery and have a copy ofthis.
Cheers
As briefly discussed, the Division was contacted by a member of the public last weekregarding the above activity and concerns over water quality in the Huon River as a result ofdischarges from this activity. The coinplaliit alleged that pollution was occurring (no detailsprovided). Advice was given to this complainant that they should contact both inlandFisheries given that they were likely to be partly responsible for regulating this activity andthat since it is a Level I activity under the E}.{PCA that they needed to also contact Councilto follow up on their concerns.
received a Gall from another member of tile ublic toda who lives in the area He
entioned that he re resents around 50 members of the community in the area
He wished to complain about the a arent lack of actioninterest by the various sections ofovc, Linent and that he bad been effectiveIy 'ven the run around on this issue with Do actual
resolution to the Tobiem.
41~P. 4R7:VENT, !froURISM. AR7:Scad, he ElmROA^IEA'7
RelL-, L-:. dimder file Freedom off, !formati@" Act 1991
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To:
FROM:
DATES
ME
FD, E NO:
BOB KA^SZXEWYCH
ORANDUM
SUBJECT:
H BOBBl
12/11/2007
2206918
111 accordance with the Eli^lipCA 1994, the Council must use its best endeavours toprevent or control acts or onfissions which cause or are capable of causing pollution.
SUG the following tilts are relevant in figlit of the email sent from Wanen Jonesthe arcs regalaxion of the Lonnavale Hatch , o Grated b 11AC.toda ,
On 29 Marc 2007 tile 11VC served an Environmental F1.0tection NoticeLtd This action was taken as a result2007/1 on the Huon A narultine Coin an
aware that the o bon and ion of the exisrinof e Council beco
Russell River Hatshery including the derelo meat of a r adon f^Gift was or
was likely to cause anyironrriental harm. The EPN included the requirements fora montlily effluent and water quality monitoring,a wastewater discharge limitts anda the preparation and implementation of a soil and water
management plan.
On 18 April2007 the Council's EHO undertook sampling of the Russell River at anumber of sites both above and below the farm outflow, to check for compliance withthe EPN, as sampling results from EIAC had not yet been received. During samplingleakage of 'tiirbid' water from the site in relatively close proximity to the farm inflowwas noted that was later clanfed as leakage from the recirculation channel.
On 20 April 2007, EIAC were advised in writing by the INC of their requirement tocomply with the conditions of the EPN with particular emphasis placed on compliancewith the set discharge limits for wastewater discharge.
On 24 April2007, the Council's EHO undertook sampling of the Russell River at anumber of sites both above and below the fallu outflow, to check for compliance withthe EPN.
REGULATION OF RUSS^LL RIVER HATCE, l^RYOPERATED BY BtAC PTY LTD
RMIEN7qfTOUR/SII, ; 4,773@"d the EN&7 I I , ',e eased ""der the Freedom @1thlamatt@" A I I ' 9
I of 2
15" I
WanenJones/ENVIRONMENT/CoRP ..
13/1 1/200711 :28 AM
Warren Jones
*Please note that my email and postal address have changed. Please update your address book*
General Manager - Environment & Director of Environmental ManagementEnvironment Division (6th Floor)Department of Tourism, Arts and Environment134 Macquarle St. (Lands Building)GPO Box I 751 , Hobart, Tas. 7001ph: (03) 62336336, Fax: (03) 62336800email: warren. iones@environment. tas. gov. au
-- Forwarded by Warren JonesiENVIRONMENT/CORP on 13/11/20071, :28 AM --"Bob Karaszkewych'<bkaraszkewych@huonvall To <Warren. Jones@environmenttas. gov. au>ey. tas. gov. au>
CG 'HeIena Bobbi" <hbobbi@hubnvalley. tas. gov. au>13/11/200710:44 AM
Subject RE: Lonnavale hatchery - Attention, Manager Environmentand Development Services
To- David. Mitchell@environmenttas. gov. auCG
bcc
Subject Fw: Lonnavale hatchery - Attention, Manager Environmentand Development Services
if.
Warren
Please find attached internal Memo, for your information.
RegardsBob
.--. Original Message-----From; Warren. Zones@environment. tas. gov. autmailto:WarrenJones@environment. tas. gov, aulSentB Monday, .1.2 November 2007/1:32 AMTo; Bob Kaki^, kewychCcs David, Mitchell@environment, tas. gov. au; Stephen. Gallaghet@environment. tas. gov, auSubjects tonnavale hatchery . Attention; Manager Environment and Development Services
Dear TVlt. Karaskewych
Please find below an e-mail naiad. one of my officers following the receipt of. acomplaint froi^ a member for the PIiblic. Council provided me with a copy of an EFT. Iissued by HeIen Bobbi earlier this year (April),
Fish hatcheries are not level2 activities and henc y e
E^it"rococo""' am^M^N^^^"f^^I^;9^I^?^^^@,*^E!!^^11^j.^TR leased under the F, ,ee on
or advise
our Minister if the matter is raised in Parliament could you advise what action Counciljus or is taking to address the public complaints. in particular I would be interested inany objective monitoring data'of the quality of emitssions or any downstreammonitoring that has been carried out.
As briefly discussed, the Division was contacted by a member of the ublic last weekregarding the above activity and concerns over water quality in the Huon River as aresult of discharges from flits activity. The complaint alleged that pollution wasoccurrii, .g (Do details provided). Advice was given to t}lis complainant that they shouldcontact both Inland Fisheries given that they were likely to be partly responsible forregulating this activity and that since it is a Level I activity under the BMPCA hatthey needed to also contact Council to follow up on their concenis.
I received a ph call from another member of the public today who lives in the area Hementioned that he represents around 50 members of the comintinity in the area_
He wished to complain about the apparent lack of action/interest by the varioussections of goveiLunent and that he had been effectiveIy given the run around on thisissue with no actual resolution to the problem.
He alleged that 11AC are discharging pollutants with gr'OSs solids, and erbaps evengrowth hormones, which is making the water in the river ,meIntoble for both drinkingwater and stock water for farmers in the region.
He claimed that Council are aware of the issue but apart from issuing an EPN seem tobe unwilling to enforce this or take any further action on the roblem. it is apparentfrom a review of the EPN, that Council certainly are aware of tins issue and follow upadvice from Council is needed
He noted that other government agencies had been contacted including Public Health,Water Resources Division, (and Inland Fisheries if I recall correctly). The advice hehad been given was that it was a matter for this Division under the Act to deal with,given supposedly Council wouldn't.
He clanried that the pollution being discharged was of a significant level and that intrying to discuss the problem with 11AC, their advice was that they were doing all theycould.
,
Clearly he was frustrated and had therefore recently engaged a solicitor to assist than,and mentioned that the media and politicians were also likely to be notified about theproblem to try to force action.
I discussed the matters with him and advised that clearly the activity is not a Level2activity under the Act and therefore this Division is not responsible for its regulation.discussed with him where I felt the likely regulatory control should lay but here-iterated that they won't deal with it.
d the EN, 'IRONME,am of TOURISM, ARTS un,,,,,,,,,, r, f ' ''''DEp, 4RTME t 1'''Rareased under t I
John. Diggle@its. Ias. gov. au1211 I 1200703:52 PM
Warren
Yes the IFS does licence this fish farm cosh farm licence number 50, licenced to Huon AquacLiliureCompany, Manager Peter Bender).
The following conditions are imposed by IFS.. The licence is issued subject to the relevant approvals, permits and licences being obtained
by the licence holder from all relevant authorities, including local council, Water ResourcesDivision (DpiW). The holder must comply with any conditions stipulated in such permits andlicences.
. For discharge into inland waters, any waste water or effluent arising from the fish farm mustbe treated prior to dls arge, in accordance with Local Council requirements. The Director ofInland Fisheries, may order in writing that the holder implement the strategies necessary tomitigate pollution and that the holder shall immediately concur with the terns and conditionsof that order.
. The holder shall ensure that all ambient water quality and effluent monitoring requirementsare undertaken in accordance with the Local Council's specified monitoring program, andshall ensure the recording and reporting requirements of such a monitoring program arestrictly adhered to.
This issue was raised with IFS over 12 months ago by a Council oncer, it was agreed at the time thatCouncil would consider the issue further and get back to IFS if additional action was required , therehas been no contact since then.
To Warren. Jones@environmenthas. gov. au
CG David. Mitchell@environment. tos. goveu,Stephen. Gallagher@environment. has. 900. au,Cindy. Gillespie@its. tas. gov. au, Phil. Boxall@its. ^s. gov. au
bcc
Subject Re: Lonnava!e Fish hatchery
I would be interested in seeing the EPN if possible, if this is developing into a significantenvironmental problem with insufficient attention from HAG, then aidnt approach from Environment,IFS and Council may be the best action to resolve the matter.
rom my understanding of the issue, the likelihood of water quality related complaints arising fompoint sources suc as fish farms is likel to increase rticula if the trend of declining catchmentyields and flows continues across tile State.
Regards
John
John DiggleDirector of Inland FisheriesInland Fisheries Service17 Backriver Road New Norfolkor
PO Box 575, New Noriolk 7140
10hn. diggle@its. tas. gov. au
DEPARTMENT of TOURISM, ARTS grid the EmuRONMENReleased under the Freedom off, !fom@lion Act 1991
Phone: 626,8060
' This copy Is not a completeI copy of the original record
14'6 ,
29 032007
Ea, "u, ",,". I Protection Notice 2007/1
N'I' PRO ECTION OTICE N . . 2007/1EN\^O
issued under the Errvironn, enrolMm?age"lent andP0//14t, o11 Control, {ci1994
issued to: B:uon Aquaculture Company Pty LtdFO Box I
DOVER 7109
"P^LEI'C;'^- Oc;' .2.^ Q=
Activity: Ri, sse" River Hatchery Redrulation Facility - I^rinavale(identification: 2206918).
I, He Iona Jan, na Bobbi, a Council Officer, am satisfied that in accordance with Section44(IXa) of the E"vfro"mental Management and Falunon Control ^ct 1994 (the ElvlPCA)and in relation to the above-mentioned activity that environmental harm is being or is latelyto be caused by the activities undertaken on the land
*-
F COPY
The gi. Dunds upon which this notice is issued are that: -
I . The Huon Valley Council received an Environmental Effects Report on the proposedFreshwater Finfish Re-Circulation Hatchery prepared by Aquaculture, Management& Development Pn in late 2006. The proposed activity is as shown in the drawingprepared by Peacock Darcey and Anderson FA, (drawing number 1606C-3A) lyingwithin Property in 2206918 ('the land').
e ro OSedinl", d fish f^Tm win draw water out of the R eU River and discbar e
some wastewater back to the river after _ _-circulation.
3. As a consequence of the emission of pollutants described in the EnvironmentalEffects report, environmental b^mm is considered to be occurring or rocely to occur onthe basis that:
a. there is an increased risk to human health and/or the environment due to the
presence of pollutants in wastewater and run-off; and
b. the proposal includes an option for on site land spreading of sludge from thesettling tonks which could lead to run-off; and
' e from odours from the above
06P. ,!RIMEN7qf70URISA, ; AR7S@"drhe EN, TRONMENT
Rel"used under, he needo, " of Infom, ",, on Act 1991
GROUNDS
c. an enviro
activities.
EPN Huon Aquseulture Reciteulation Farm
.
ale of issue. 29/03/200
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1.4-lib. (.;-266'1 148515 FL^I VFLLbY L, ^^ I L
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Engi, ," to
THE REFER^CE ON LL CORRE^NDPNCE
08/08
ABN 77 6022, ,7 nZ6
14 Deedn er 2007
Geol, 'Cockai"
Mr Mark ' May383 Loini ale Road
Fax: 6266 0339
Dear M
I^UsS^I, RIVER
With ref CG to the above and our recent conversations, I confirm the followingmatters:-
have advised me that all fish currently in tile ponds of the now-throughI. Ben
hate my are to be removed immediately and placed at sea.
2. Tile nly fish that will remain in the flow-, 11roug!, ponds vim be 3040 broodfish.
3. All er fish will be retained in the re-Gincolatory hatchery.
4. Mr ohn Dobson from the Environmental Division investigated the siteide, , fi by tti complainants, took samples and has advised Council that bewill provide copies of the sampling results to both Council and theco lamerIts as well as photos of the sites.
I trust tba the actions by Bender in removing fish stocks fi!Dan the now-throughhatchery p rids will sig, incaritly reduce any potential impacts on the water system ofthe Russell ver.
If there are y other developments, I win be in contact
Yours fat
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GENE ,"ACEl^
ToTRi. P. 01
,'Halena BobbF<11bobbi@huor, valley. tos. gov.aU>
3/10/1200803:24 PM
Hist
Hi Sarah,
Our planners have advised of the following regarding the need for planning assessment of the expansionof the HAC hatchery at Lonnavale:
Under the tovisions of Schedule 3 of the Huon Planning Scheme 1979, the use andactivity at the site is defined as ag, ,. culturel and is considered to be "PI" thus does not
application.assessment or a prequire p
To <Sarah. Richards@environmenttas. gov. au>
co 'HeIena Bobbi' <hbobbi@huorivalley. has. gov. au>
bcc
Subject FVV: coringvale Fish Hatchery
sbeeizJ:^plied ossage
.
Probably a good idea to contact Leigh Stevens (Senior Town Planner) if you require further explanation.
regardsHeIena
.
--Original Message-
From, Damn Hutchlnson
Sents Thursday, 31 January 20083'18 PMToe Halena Bothl
Subjects Lonnavale Rsh Hats!'lay
Under the provisions of Schedule 3 of the Huon Planning Scheme 1979, the use andactivity at the site is defined as agticulttital and is considered to be "PI" thus does notrequire planning assessment or a planning application.
Damn D. HutclitnsonDr an Rural & Env. Planner
Hi/@" I, '@"^y Coffin7P. 0. BOA. 210,40 Mar7? 5'7ffr/H, /@muffe, Tar, /PIMb, 71 09
DEP, 4Rm4EN7qf70URISM ,4R7;Sand, hear, 7RONEP, 4Rm4EN7qf70URISM ,4R7;Sand, hear, 7RONMEe eased under the F, .eedom @11, !fom@!^b" ^of 1991
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Assessed by the Department of Primary Industries, Parks, Water and Environment under the Right to information Ad 2009
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.,^Tasmania
inland Fisheries Service
17 Back Rinr ^I, h^ Nofdk^S 7140PO B^575. New1\101fdk. us 7140fus"'ana
Ri (03) 62618050 Fax (03) 62618051BinB tr@@I^toegy, u ^^ unw. Ikbs. ^, an
Licence Number:
Licence Holders
CompanyliB"singss Name:
Address:;'>
FISH FARM LICENCE
17n1,2nd risingneg, !, of 199^;I
Datelss"co:
Expiry nate:
50
Peter BENDER
Huon Aquaculture Company Ply Ltd
PO Box I
DOVER TAS 7117
I September 2007
31 An at 2017
111 accordancewith them JamdFisheriesAci1995, this Fish FomLicence authorises the
holder to cultiire/farm the declared species of rainbow trout (Offcorky"ch"s ,mykiss) and
Atlantic salmon (S@!"to salar) only for commercial purposes, in respect of the fishery
situated at Lot N0 33640, Russell River Road, miniavale, Tnsmania subject to the
Conditions of Licence specified in Appendix I.
blandricher, es,.. V, C.
^,,
Only those premises specified in Appendix 2 may be used in connection with the
production, storage, treatment or disposal of fish from the fistiery to which this licence
relates.
,
Director of inlandli'isheries:
Date:
SIg""t"re of Licensees
Date:
his is not a
complete COPY ofthe original record
.
.,..,^.,^,;^..^^\^^^:.....^^^............. .....
Assessed by the Depariment of Primary industries, Parks, Water and Environment under the Ri ht to Information A t 2009
APPENDIX I
CONIDit, :110NS 018'1, IC^NCE
EtchFannl, iconoe110 Soto i, suedin accordance with the fill""dF, siter, 93 ^6,1995, andi, suiteottothe following condition, :
I. This licencei, issued forthepropagationand on, gowiijgofAtlantiosalmon(&, hog@!"r) andrainbowtront(ate@,*y"char"ayu8, ) onlyand only on the^anises stated infoi licence.
2. The licensee. channel extend the read"g of an beyond the gpeole, nor Fraud8e, coveredby big licence without the written consent of", a bland Eitheriea Sum'CG (IFS),
3. Fish sinkB than be chinfried only from flab fbnns within Tasm, "Ia as neonaed with the inlandFi Service.
4. Flab than not be by oiled from intentste or overBoas onto the premises to which @11s licencerelates.
5. 7110 Econsee, dull not sell or CG^r or Garnigi for sale any fish not raised on the prenitses towhich this licence relatco, ^^more, an interstate fish Gales must comply with thenewt^us of the applicable an^
6. The namee, aball take all reasonable precautions to vent the escape of any flab or theframer of amyl18b dtseaee from the fighfa, into other inland waters, indriding flood mitigationshalegio, ,
7. The licensees are to participate in the Peparim^t of Pd, ^y ladu, tries and Water gainaddhealth omananee prog". at a level conure"unto with the financial comint, udon andpatio!pation prevailing tom time to time by Balmonld grower, licensed under die Lit*, gMat, eR"@", aerM@"@gema, ,, err995.
The Ikea8eea sham finm", 1,161y notify the Director orbl. rid Ficherie, and the Chi V I furyDepar", cot of Primary Mus^log and W. toy of any ,i^lacent fish or ova0,110er of
morality with Lithe fi^. farm to ^ this licence rentsB.
Where it is considered Ileum"y to control th, 8pread of disease, the Director of InlandFishede^ in GonadtatiOL With the Chief Veterinary 06dcet, may order in writing that alemumee, cease 108 11 on^, or cong:gn for"I^ or bang^tony fish :6:0m the promtse, to whichtill8 licence relates and that the licensees ehalI jam, "thany coneur with the terms andcob, ithns of this order. Any such order chain remain in effect until revoked in writing by theDirector.
Before discharge fulloinland waters, anywas!ewater or effluentari, ing from the fish fom mustbe to Ib, Gadefoction and in accordance with local Council. The Director, bland FitsherlesService, nay order in illdiii!g that the rice^CG implement strategies neges"Iy to mitigateconch'on cod the licensees shall tinnedfuely concur with tie tenrs and conditions of lintorder.
The licensees sham omuro that at 8111"lent water quality and danent monitoring requirementsare Laded aka in accordance with monitor^g program sjisc^ed by the Eruon Valley Counem,and charr ensure the recording and my or^ing requirements of such a monitoring pro^in arestrictly adhered to.
Water chadactlon and aasooiated monitoring reqiilrement, must comply with the condition, ofthe Water Dance to which this flab form. relates as issued by the Departnent of Pin^yladuBtrlo, and Water.
,
Upon reasonable request, an. officer of the bland Fisheries Service than be granted aceeaa tothe premise. ,poemed in this neoncq and the licensees shall cooperate by bombti, 18inspection of premises and figh harem and by providing any further information sought by thato11^o00
This licence is fumed subject to the relevant approvals, porn, lis and licences being obtained bytheftc"1006s fom all 1.18van, I. ^n.
a.
.
O.
I.
3.
.
15.
o
.
Assessed by the Departrnent of Primary Industries, Parks, Water and Environment under the Right to information Act 2009
The Beensees are required to keep Gol^pieta and Beamate reamds of all fi^, br0^11 onto, orconsigned fro, ,^ focitoawipremises as sho^in on the attached profonn", with those recordsbeing kept for five yeare.
with Section 51 ofThe licensees sham mintsf" con^, late and accurate records in 8000the InlandF7sha. leg^err995 coachallmale gushreeorda arenable to an officer of the rnl. in,Ficherles Service uponrequest.
T^encore^ shall 81thwit an an unl room to fog b^d F^ie8 ^ice and each reinm thanbe in accordance with ftie req^mm of the Service.
This licence is issued in accordanee with the turnmulinn and pa^ars prov^ in the finalBPFlicatloiL Developniemt and operational coliviti must be^Mate with the petaaitarsof ale final application. Any variation or extension runt not proceed without the prior andwritten approval of the inI'm, Fig^cries Service and Hmm Vat^y Council,
This licence is subject to annual feeB, with the preserfbed fee payable to the inland FisheriesService each year mule this homee is in force.
o
20.
Note: Falltte to comply with any condition oniconeeis un offone',.",,,, Section 42(4) of theftlmidr'skeri^, o, 1995 and, under Section 48(I) am zeniti. thencencebeing co. caned
AprilBNDIXZ
The following p. ", fires only tray be used for activi^, authori^ under ^,. I^ boil^ theproduction. storeg^ heath", n, ,r disposal of^sh thrifta^form:
Loligo 33640, RutseURoad, innn"vale, T. "mala
o
210
Department of Tourism, Arts and the EnvironmentENVIRONMENT DIVISION
Level7, ,34 Macquarie Street, HDbait TASGPO Box I 751 , Hobait, TAS 7001 Australia
Enquiries:Ph:Email:
Web:Our Ref:
Dan'd Mitchell+61 362336504 Fax +6,36233380o
Dadd. Mitchell@onvironmenttas. gov. auWWW. environme_nt. Ias. qqv. au
(EEOnS/FF/SIFIAC/HuonNov_On sina
I9 November 2007
Deari
I refer to your conversation with my officer. David Mitchell, on I2 November 2007, in relation toyour concerns and those of other residents in the Lonnavale region regarding Huon AquacultureCompany's (HAC) fish hatchery at Russell River. Lonnavale.
I am advised by my officer that in particular your, FoilCeriis relate to the quality of discharge waterfrom the hatchery site to the Russell River' an^. the inip66t;,{it is 'may be having on drinking waterand stock water quality, as well as problenjS I^it^1'^ui^^'bloc^a^6s. I further understand you weremost concerned that, despite some a^ions- flaying been;tai<^Ii' by Council and your attempts todiscuss the matters with EIAC, it appeared ther^. had been, *no, improvement in the current situationand therefore you have sought to bring this mat!e'r' to the' -a^eption of various State GovernmentAgencies.
As discussed with you by my officer, fish hatcheries are not classified as a level 2 activity under theEnvironmental Management and Poffution Control Act f 994, but are classified as a level I activityand therefore regulated by Council (the Huon Valley Council, in this instance) in accordance withthe provisions of the Act. It should also be noted that, in addition, HAC are required to hold a fishfarm licence from the inland Fisheries Service (IFS).
it is understood you were notified thereafter by my officer, that as a result of you bringing thismatter to my attention, an undertaking was given to discuss the matter with the Director of InlandFisheries and the Huon Valley Council (FNC) to ascertain precisely the nature of the problem andwhat actions the appropriate regulatory authorlties had or were undertaking to ensure itsresolution.
Re:
DEP^RIMENTqf70URISM;, R7S@"d, he ENl/IRON, \/E\
Rat, ,, sad ""de, the Freed in 9/1, :formatio" hat 1901
HUON AQUACULTURE COMPANY PIL FISH HATCHERY DISCHARGES
This conv is not a coinplettcopy ,!I !ik, ^ . 141 ramrO
^,./^,- I
^
Tasmania
^
^
I am able to advise that as a result of my discussions, the IFS stated that the HVC had been incontact with that Agency to discuss problems with the EIAC operation in terms of impacts due toeffluent quality discharged to the Russell River, which in part may be due to increased operationsat the site.
Advice received from Council stated that as a result of these concerns it had issued HAC with anEnvironment Protection Notice (EPN) on 29 March 2007, aimed at addressing a range of problemswith this site, including the requirement for compliance with discharge water quality limits, regulardischarge water quality and river water monitoring and reporting to Council. in addition, as a resultof non-compliance with a number of requirements of the EPN, Council also issued anEnvironmental infringement Notice to HAC.
I4^'o .
On the basis of this I am satisfied that Council, as the appropriate regulatory authority for thisactlvity, has taken an active regulatory role in managing the activity.
While Council is the appropriate authority in this instance to regulate HAC's activities and hastaken active measures to limit the impacts, in view of the ongoing problem I have offered Counciltechnical advice and assistance to help identify further actions that can or may be required.
it you require further information in respect of this matter, I would recommend that you contactCouncil's Environmental Health Section.
Yours s' corely
en JonesDIRECTOR OF ENVIRONMENTAL MANAGEMENT
GPrtR1;1.1ENTqfTOURISA-,; AR7:S@"d, he EN, TRONME
Rel, "sad under the Freedom @11, !formation Act 1991
I^I
Department of Tourism, Arts and the Environment
EPAR7MERTqfTOURISL4 ARIS@"dtheEN, TRONMENT
Released under the F1^11r^"p^1:0 0 N D U M1,0772
Warren Jones
Floyd Browne, David Mitchell, Stephen PreftenExr: 6659Sarah Richards
31 January 2008
Regulation of Huon Aquaculture Company hatchery on Russell River,Lonnavale.
File No:
To:
CC:
FROM:
DATE:
SUBJECT:
Hi Warren,
The complaint investigation of the Huon Aquaculture Company operated hatchery at Lonnavale on I7December 2007 found evidence that the activity was affecting water quality in the Russell River.
There is an existing flow through system and a new recirculating (90% of inflow) hatchery developmenton the site. The non development did not require a planning PPIication under the ESPeran co PlanningScheme and therefore does not require a penniL Huon Valley Council issued an EPN in March 2007to address issues with water quality being discharged from the flow through system. No environmentalconditions have been required for the new development. The new development is already in partialoperation and was still under construction on I7 December 2007.
On 29 January 2008 a meeting was held with Huon Valley Council, Water Resources, inland FisheriesService, Aquatic Health and the Environment Division to discuss the regulation of the site.
in terms of regulatory jurisdiction Water Resources are concerned with water allocation licences ande inland Fisheries Service is concerned with species beingmaintaining environmental flows.
stocked and production rates. Council regulates the general environmental conditions of the activity,including quality of discharges to the. river. While Council have issued an ER^I and an EIN HAC arestill non^Qin nant with discharges to the river.
Water Resources report that the Russell River has had low flows for the past four years and that thecurrent wate allocation licence is no longer appropriate to maintain environmental flow. The flow in theriver is not sufficient to rovide dilution of pollutants discharged from the flow rough system. WaterResourees have required HAC to submit a study of the river ecology to denronstrate that they are notaffecting the downstream habitat if they are to continue to take water from the river. EIAC also areseeking approval from Council for a mixing zone for their discharge. I
^..,^.^-- I
9.11'. InTasmania
.
The ongoing operation of the new hatchery, the flow through system and its discharge to the river needelf^live regulation. I recommend that the Environment Division (myself as regulating officer withtechnical assistance from Greg and Stephen) regulate this activity to require sustainable managementplans for both the existing flow through and the new hatchery. it is necessary to set and enforcesuitable discharge limits for the water returning to the Russell River.
A site visit with Council, Water Resources and Inland Fisheries is being conducted on Tuesday 5February 2008. I will prepare EPN after that.
, ..,-^--,=-- ~. -L____-,.
Sarah Richards.Senior Environmental onicer, Food and Textiles Unit
al
This copy is not a completecopy of the original record
Z. ... .
Department of Tourism, Arts and the EnvironmentENVIRONMENTDiVISiON
Lgye17.134 Macquarle Stoat. Ebbart TASGPO Box 1751. Ebbarl. TAS 7001 AUStraRa
Enquiries:phi^initWeb:OLr ReE
Sanh Ridiaids+6,362336659 Fax +6,362333800Sanh Richards@emitonment. Ias. gay. auwanenvironmentfas. gov au1,0773: FFISIHAQHVCHAChalcheryLltcoOIOB
4 February 2008
Mr Geoff Cockerill
General ManagerHuor, Valley CouncilPO Box 210HUONVILLE TAS 7109
Dear Mr Cockerill
ENVIRONMENTAL REGULATION OF THEHUON AQUACULTURE COMPANYHATCHERY, LONNAVALE
I refer to the hatchery operated by the Huon Aquaculture Company (HAG) on the Russell Rivernear Lorinavale. This site has been the subject of several complaints that related to the impact ofthe hatchery on the water quality and protected environmental values of the Russell River.
in response to complaints made to the Environment Division regarding the hatel'Iery, officers of myDivision conducted site inspections on 8 and 17 December 2007. These inspections found thatthere were was an apparent detrimental change in water quality in the Russell River adjacent toand doomsfream of the hatchery. It was also observed that a major redevelopment of the si!e wasbeing undertaken. that the new hatchery was in operation and that there was a discharge ofwastewater generated by the activity to land.
in addition to problems with the operation of the existing earthen aquact. inure system. I amconcerned that the new developrnent is a large scale activity that has the potential to causenvironmental ham. I am advised that this developrr, ent, under the ESPeraloe Planning Sclieme,did not requi a iannlng appmcaliDn as it was considered to be an existing and permitted use. Aresult of this is that no fomal assessment of the activity has been made and nerdbre nocomprehensive antimnmeriial conditions have been datemiinedlbrthis activity.
I am advised that on 29 March 2007 Council issued Environmental Protection Notice (EPN)2007/1. under section 44(2)(a) of the Environmental Management and Poffutibn Control AC 1994t.to HAG. This EPN required them to address environmental issues associated with both theconstruction of the new development and the effects of the operation of the existing hatchery. I aminformed by Council that HAG is in non-compliance with this EPN with regard to emission limits fordischarge to the Russell River and in the provision of information requested by Council.
On 29 January 2008 a meeting was held with HeIana Bobbi and James Wood from Council, andrepresentatives from the Water Resources DMsion. the inland Fisheries Service, Animal Healthand Welfare, and the Ei. Ivironment DMsion. The Water Management Branch reported their recordof very low flows in the Russell River over recent years and advised that currently natural flow inRussell River is significantly less than the envirohmen al flow triggers attached to the HAG waterlicence. Pollutants in the water being returned to the river after use in the hatchery oreate a highlevel of environmental risk to the river in this low flow state. These matters also impact on downstream water use of the Russell River which includes potable water irrigation, 510d: watering and
contact recreational u eprima
^..^.. I
^I'_^Tasmania
DEP, IR2ME'NTqf70CR^I. ^R7:Sand, "earn'RONMENT
Released under the Freedom of", format@" ^of 1991 ^, O.
The Water Assessment Branch advised that for the purposes of applying tile ANZECC guidelinesin setting discharge limits, the Russe" River at the site of the hatch , is an upland river. This is onthe basis that it behaves like an upland river, is short in length and has a relatively steep gradientin comparison to mainland examples.
I also advise you in relation to HAGS request to Council for approval for the use of a mixing zoneto detemiine their discharge limits that this is a matter hat may only be determined by tit^ Board ofEnvironmental Management and Pollution Control in accordance with the State Policy on WaterQua"ty Managen, e, it. The use of a mixing zone is not generally considered to be appropriate for aconfined, low volume waterway such as the Russell Rivet.
in summary, the following environmental issues have beat identified with the hatchery:Seepage fom tile flow through cystern to the riverDiscliarga of conutants to the ite via the out1^11;Volurrre of haler diversiDn from tit rhar does nat allow for emu'roninental flows'impacts to donristream users of the river
fom the new hatchery;Emuent heathient and disWas, a managerI^11 and disposal from the new hat"18ry.
Due to the potential of this activity to cause envlmyiniental ham and the complexity of theenvironmental issues at the site, I am proposing to assume regulation of this activity until such timeas the current environmental problems are resolved and the facility is operating on a sustainablebasis. However, before ace, ,ming regulatory responsibility for what is a Level I activity, I seek yourCouncil's comments on, and agreanent to, this approach. To regulate the activity I will be issuingan EPN under section 44(, Xa) of EMPCA in due course. When that EPN has been issued I willask CDur, cm to revoke EPN 2007/1.
I would appreciate all assistance that can be provided by your officers in tile hand over of theregulation of this site to the Environment Division.
Please contact Sarah Richards on 62336659 if you have any questions about the above.
You sincerely
DIRECTOR OF ENVIRONMENTAL MANAGEMENTJones
CG Mr Martin Read, Manager. Water Assessment Branch, Water Resonrces, 13 SI JohnsAve, New Town, TAS 7008Mr John Diggle, Director. inland Fisheries Service, PO Box 575, New Norfolk TAS 7140
an'of TOURISM, ,RTS and thed rider the Freedom of I, !font"do ?
^I^
,,,,~^^ Sarah, , Richards/ENVIRONMENT/Co
, , RPa ,
,
,
Hi Warren,
I received the following email from HVC re hatcheries They are .Nil!ing to hand over HAC
18/03/200805:36 PM
in regard to the HAG hatchery, we have been receiving more coin laints. Tony Port has conductedsampling on two occasions. I spoke to I today and he advised that there are still issues withthe river and that they will I'~ '.^ving a community meeting soon with whatever press they can get (60
also stated that he is seeking legal advice for a class action.minutes, A current affair).
I have been waiting for a response from Council allowing me to proceed with regulatory action. I willprepare an EPN for the hatchery to issue asap I havejust met with Doin O'Brien and David Molehead todiscuss the HAC net wash and raised the issues of the hatchery as well. I feel that the workingrelationship with HAC is positive and that they will comply with our requirements.
To Warren Jones/ENVIRONMENT/CORP@CORP
co David MitchelVENVIRONMENT/CORP@CORP. DarrylCook/ENVIRONMENT/CORP@CORP
bcc
Subject Hatcheries in Huon Valley
Cheers,
Sarah.
Sarah RichardsSenior Environmental OfficerFood and Textiles UnitEnvironmental Operations BranchDepartment of Environment, Parks. Heritage and the Arts
,
GPO Box 1751Hobart TAS 7001
Ph: 0362336659
Fax: (03) 62333800Email: Sarah. Richards@environmenttas. gov. auinternet: WWW. environmenttaS. goV. aU-- Forwarded by Sarah Richards/ENVIRONMENT/CORP on 18/03/200803:19 PM
'Hannah Mathews'<hmatlhews@huonvalley. tos.gov. au>
18/03/200803:17 PM
, F^.
I Py is not a completeCopy of 'ompletee original record
Hi Sarah,
I have just spoken to Bob and he has informed me that a response has been prepared, is currently with
DE. "ARTMENTqfTOURISA. ,;, R7:Sond, he ENJO'RONMEN7
Reinised winder the Freedom @11, !formation ACi 1991
To <Sarah. Richards@environment. Ias. gov. au>
Subject HAC Lonnavale Hatchery
co
^cf ,
.,'Hannah Mathews'
<hmatthews@huonvalley. tos.gov. au>
18/03/200803:17 PM
History
Hi Sarah,
I have just spoken to Bob and he has informed me that a response has been prepared, is currently withGeoff and should be posted today. Bob said the letter basically states that Council is haPDv for theEnvironment Division to regulate the HAC I on navale Hatcherv I. .
bcc
Subject EIAC Lonnavale Hatchery
This message has been forwarded.
r
' r. , n O'
Regards
To <Sarah. Richards@environmenttas. gov. au>CG
Hannah
L ~
HannahMathews
Cadet Environmental Health Officer
Huon Valley Council40 Main Road, Huonville 7709
Ph: (03) 6264 0356
Disclaimer/warning - The infomiation contained in this email ar, d any attachments is confidential and is intended for the attentionand use of the named addressee(s). This information may be subjecl to legal. professional or other privilege or may otherwise beprotected by intellectual property laws. work product immunity or other legal rules. This information must not be disdosed to anyother person without direct authority from the original sender. If you are not the intended recipient or a person authorised to act onbehalf of the intended recipient. you are not authorised to and must not disdose. copy. distribute. or retain this message or any partof it it you receive it in error, please let us know by return email. delete it from your system ar^ destroy any copies. Anyunauthorised dissemination, copying or use will result in legal action.
Any views expressed in this message are those of the individual sender. except where the sender specifically states them to be theviews of the Huon Valley Coundl.
This email has been checked by up-to-date and current virus checking software however Huon Valley Council does not guaranteethat any attached files are free from computer viruses or defects
.1.1
This copy Is not a completecopy of the original record
,
ENTqjTOURISM, ARTS @11 tcored ""der the F, . adorn of Iofo, in" '
,
c ,a ,
*
,
SarahRichards/ENVIRONME, fr/CoRP
I9103/200802:44 PM
, I his copy is not a completej copy of the original record
Conversation with
slated:
- That the Russell River had deteriorated further and that the river was full of algae- Main issue'is that the river is no longer good enough for drinking from or am'mining in.- On weekend had camper there who could not enjoy the river because of the poor water quality.- Complaint against Hydro work on his property without consultation with him and an unnotified longpower outage. Installation of power line to hatchery.- He is leading a community legal action, now with lawyer seeking advice against HAC.
- Requested data from recent sampling work by Tony Port (19 Feb). if it can't be providedwritten statement to that effect.- a public meeting and media coverage were in process of being arranged.- very frustrated as they have been complaining to council about this issues for several years and havenot had any real response.- HAC lied to them in saying that they would only be using the ponds on the flow through system for 30
' knows that the ponds were relined in preparation for use.brood stock
- Angry that there was no opportunity for public comment on the hatchery developmenL 'They just getwhatever they wariV.
To Warren Jones!ENVIRONMENT/CORP@CORP
co David MilchelVENVIRONMENT/CORP@CORP
bcc
1,5518 March 2008
Subject Lonnavale hatchery detailsi^
I said:- Results from 19 Feb did indicate that there was an increase in nutrientlevels downstream from thehatchery but that these levels did not represent acute environmental harm and that Environment would nottake enforcement action at this time.
- Environment Division could nottake further regulatory action until response from Council was received.At this time we will issue an EPN on the hatchery, review the environmental management predices for thesite and take necessary actions to enforce the EPN.
There is the sibilily for an environmental nuisance case but I would need to discuss that with CISsection head.- I regard to provision of data I would need to check if we could release the data to the public and wouldprovide a letter of explanation if that was not possible.- Einission limits set in Council EPN were not appropriate for the site as Council used the fowland river
ANZECC guide where Russell River at that location Is considered to be an upland rive- I advised that I would keep ! informed of actions by the Environment Division to regulate the site andasked him to keep me informed of his actions in this matter.
Other info
- The new hatchery development gets it full water supply from a bore on site and does not take water fromthe river. Discharge from new hatchery is held on site in wastewaler dam with an jingation disposal.Solid wastes are removed from the site.
- HAC were carrying a lot of stock in the flow through last year and destocked during summer. They willnot use the ponds in the same way again, but will still have stock in the flow through- Water from the river is directed to the "old" hatchery - the earthem pond flow through system. Thisincludes a series of new tanks that will be used as for grow out of smaller fish, more individuals but lessoverall biomass.
- The tanks have a better system for solids removal from fecal and food waste and a drum filter has beeninstalled to further screen solids prior to this water being returned to the flow through- HAC identified remedial works to the pond system and have made a commitment to do these works (notime frame given)
wanted
DEPAR7^79/10L", 1814. ,R7S@, dike^VPIRONMENT
Released",,^. the FF^adornqfl, :fomatin, Act 1991z. .. ^ ,
ESnMATES COM1"11 I =I= BRIEFING
BUDGET 2008-09
DIVISION NO:DEPARTMENT:
PORTFOLIO:
OUTPUT GROUP:
ISSUE:
Responsfole Officer. ' Sarah Richards
.Environment, Parks, Heritage and the ArtsEnvironment, Parks, Heritage and the Arts
RUSSELL RIVER
No.
During the period from December 2007 to March 2008 theEnvironment Division has investigated complaints of thedischarge of pollutants to the Russell River from a salmonhatchery near Lonnavale that is operated by the HuonAquaculture Company.
in consultation with the Huon Valley Council, the InlandFisheries Service and the Water Management Branch of theDpiW, the Environment Dlvision has assumed directregulation of the hatchery to resolve environmentalperformance issues of the hatchery.
Name
An Environment Protection Notice will be issued to the
company in the near future to further address the protectionof water quality in the Russell River and other environmentalperformance requirements for the hatchery.
To address immediate issues with discharge of pollutantsfrom the flow through section of the hatchery the companyhas reduced stocking in the ponds on the flow throughsystem and undertaken remedial works on the ponds toprevent stirring up of clay.
The company has commissioned an ecological study of theRussell River to assess algal and invertebrate communitiesin the river to determine environmental flow requirementsand the effects of the hatchery discharge.
DEP, IRTMENTqfTOUR/SLf; ARTS@,, dthe ERP7RONME?VT
Released under the Freedom @111!formation Act 1991
Environment Parks, Heritage and the Arts Page I 19/05/08,3.00
61 .
Letter from Gay Branch who lived at 1046 Lonnavale Road prior to the Swan family taking up
residence. Gay Branch is known to the Swan family and at the time of this letter she was
employed as a Housecleaner for Peter Bender.
Everything she reports is contradicted by the local residents including one gentleman (MaxHelm) who is now in his 90's. And again no reports of any algae upstream ever in the RussellRiver.
13'h August 2010
To Whom it May Concern
My name is Gay Branch and whilst I now reside in Huonville I previously lived at Lonnavale adjacentto the Russell River from approximately 1974 to 1998. I lived in two houses in the area. Initially
group house which was destroyed by fire and then a second home that I lived in with son. I lived inmy second home for approximately 22 years and moved to Huonville when he was aged 10.
My only access to household water was to pump daily from the Russell River to a small header tank.I have clear recollection of there being long bright green weed in the river from when I first became
a resident. it was always worse in times of less flow and was not usually visible in the winter monthswhich coincided with consistent rain and run off.
When my son and I live at Lonnavale we regularly swam in the river and used to notice the weed.
also observed platypus at that time.
The weed when it was more apparent was always worse in the areas had "still' to less water
movement. In the inid 1990's the weed was so bad one summer that I telephone the Department of
Primary industry to ask them if someone could come and have a look at the weed. it was choking the
inlet for my household water pump.
An officer came to visit and took samples of the river and the weed. He also looked around the
general area up and down the river. I do not recall his name or know exactly what department he
was representing. He made comment to me that he felt that the weed was worse because of the
low flow and the possibility of nutrient runoff from pasture above my home into the water course
I know of other residents that attest to the green weed always being a feature of the Russell River
for many years before the fish farm was started by Chris Hill and Sue Healy.
I hope this information may be useful
Yours sincerely
I
in a
Gay Branch
27" August. 2010
Wari'GII Joiics (Genci';11 Millingci')I^FA Division
I)cpaitiitciit of 1'1'jinary industries, Pal'kg. \\'incl' and FnviroiiiiicI, cvc1 6
134 Mac(Iuarie Street110bait I~As 7000
AUST'RALIA
Re:Russell Ri\ ei.
Dear win'roll,
DEPT O Plait ARY INDUSTRIESPARKS. wAi ER & EMIRor, MENr
\\'c enclose heI'c\\, illi repori to o1^I' Cornp;111>' Incl, :Irc, I by Pelci' Din jus ill DCccml, cr 2()09twilli'essiiig water quality sailipliiig ill8 siic}; till I I occasions bel\\, cull rillay 2008 & lullc 2009.
\\!c do so on 111c basis that it is \, o1uiitarily 11rt}\'illc(I "ill collti(leiic!e" PUTSuan1 10 Suction 39(1) o1' Right to infoi'matioii Act 2009: Din'ICs' inklciitliiiii to tile 1<cpori, \\111cli we fun, ccoiniiii:, sinned ;Is a maticrofurgciicy is 1,111\illc(1,111 Iiku basis
\\re Irtist that 111c Departinciit \\, ill I'Giltiiii 111,111 hikiiig ally it:Kilniilistrati\ c" action (c. g,
17 AUG
I;. I'. N) until \\, c 11a\'t: had Inc OPP(111uiiily o1'jointly I'cvic\\, ing 111c Relic, rt & inc Stilllcnicnl
HOBART
given our funi11clicf111al ally glow!11uI illg!IC, o1'\\, 11icliI'ccciit complaint 11as appal'ciitly bcciimatic. calmot lie ascrihe(I only 10 111c UPCi';11i()11 111 (iur 11:11clici'y tit 111e leducc(I 'fuerl' IC\'clICcciiiiiiiciitled by Din^ics \vliicli, us (lisclt}sect in 111c 'chill'I' now enclose(I, had bccii
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I'. I. BCndcr (I\jailagiiig Dii'ccitii)
Richards, Sarah (Environment)
From:
Sent:
To:
CG
Subject:
Sarah,I will follow up at the hatchery for the nitrates samples being taken for the creeks from the irrigation land, however,again these are all downstream of the outflow and the tributary. in terms of sources of the ammonia at the outflowwhich we discussed, this then follows a fairly obvious pattern of being higher from those parts of the flow throughsystem that have the stock in a the lime and are feeding. However, again the actual for the ammonia are low at 50mdownstream and negiigible I would have thought for Lorkins. Also there really is no sign at present for any elevatednitrates getting into Ihe system anywhere really. But we need to defer a little to Peter on this.
@huonaqua. comau >Wednesday, 20 June 20121.0:59 AMRichards, Sarah (Environment); p. e. davies@utas. edu. au
RE: Russell river algae
From: Richards, Salah (Environment) [mailto:Sarah. Richards@environment. tas. gov. au]Sent: Wednesday, 20 June 2012 10:22 AM
@utas. edu. auTo: LCc:
Sub, c, .. . r\L. itu>acii ,, a a c
Than!<s for the updat
it is a concern that this kind of bloom 15 occurrin in winter. is it possible tha nutrient in uts from the hatcheoccurrin that are not be in icked up by the samplin ?
Has he detailed samp ing, as discussed at our last meeting, been condu red?
Cheers
Sarah
From;
Sent: Wednesday, 20 June 20129:58 AMTo: Richards, Sarah (Environment);Cc:
Subject: Russell river algae
huona ua. coin. au
Sarah/Peter,There has been a recent increase again of algae in the Russell river and this has given rise to a thick "bloom" of green
alerted to this during the middle of last week I went up to the river last Friday inalgae at Lorkins bridge. Theresponse to this to get that algal sampling done that we discussed recently and to take a further series of nutrienlssamples.
I found that obviously Lorkins had a thick growth of green algae and that this decreased upstream as we might haveexpected. However, at the outflow to the farm the green algae although not as luxuriant as at Lorkins (site 7photo)was still quite thick (site 5 photos, not great admittedIy but under the turbulence similar to the inb photos) andextensive but that in the adjacent small tributary (site 5 inb) whose inflow is upstream of Huon's outflow and thereforeit is unaffected by it, the growth of algae was as thick and widespread in that part of the river as the Huonoutflow. Presently this suggests that obviously the growth in the river at Lorkins is not necessarily (and certainly notwholly) due to the nutrients from the Huon outflow. There were signs of green algae also at the inflow to the farm (site
huona 11a. coin. aul
.,
t^atas. edu
are
I
Geoffre Swan
Subject:
From: In Fish OFS) mailto:infish its. has. ov. aulSent: Friday, July 4,201410:29 AMTo: Geoffrey SwanSubject: RE: Degradation of the Russell River
Hello Geoffrey,
Thanks you for your thoughts on the Russell River.
The issues in the Russell River came to a head during the worst for the drought leading into 2009 and there has beenfocus on the fish farm operations since that time. Flow through systems are no longer considered best practice withall new large fish farms and expansions adopting recirculating systems as industry best practice, in this regard I willbe looking into the Issue you raise about brood stock densities. The existing flow through farmoperations including the Lonnavale hatchery are being reviewed by EPA and IFS with the aim of incrementalimprovement in waste water treatment to reduce nutrient loadings and deliver improved environmental and waterquality outcomes.
The issue of fish stocks in the Russell River may or may not be related to water quality issues in the catchment, overthe past two years depletion in riverine trout populations has been reported from catchments across the State, thisis thought to be due at least in part to increased cormorant populations following the breaking of the drought. TheIFS has fish survey Information from the past two summers available on the IFS website, basically they confirm theobservations of anglers regarding reduced trout populations with the 2014 survey showing signs of recovery. Thelast major event of this nature was observed in the late 1970's with impacted catchments recovering within 6 Years'
FW: Degradation of the Russell River
I am happy to discuss this further.
Regards
John
10hn DiggleDirector of inland FisheriesInland Fisheries Service17 Back River RdNew Norfolk TAS 7140
PO Box 575New Norfolk TAS 7140
di to its. tas. ov. au
0361653810 - Phone0409550546 - Mobile0362618051 - Fax
"CONFIDENTIALITY NOTICE AND DISCLAIMER
Please note that my phonenumber has changedI
Department of Primary industries, Parks, Water and EnvironmentEPA DIVISION
FILE NOTE
ActivityDate/time
File number
Document reference
Prepared by
he EPA Division has been regulating the HUON fish farm at Lonnavale since 2007, triggerby a period of high coinp aints about river condition at that time; however, an EPN has not yeeen issued for the activity. Since 2007 the quality of the discharge to the Russell River has
greatly improved due to reduction in stocking and feed inputs in the flow through farm and theinstallation of a drum filter to remove solids from a series of tanks that form part of the flowthrough farm. River condition has greatly improved since 2007 as a result of the consequentlyimproved discharge water quality. Despite these improvements moderate density algal bloomsare still occurring downstream of the outfall.
On 28 August 2014 sampling was conducted of the Russell River to investigate the impact ofthe Huon Aquaculture (HUON) fish farm discharge on river condition following notification of ahigh algal cover. For high algal cover to occur at this time of year short day Ien Ih and Golwater temperatures) and so rapidl following a o0d event (end of Jul indicates Iha the algaeis responding to a nutrient input.
The following five locations were visited. An inspection of bank condition and tributaries wasalso conducted.
Huon Aquaculture - Lonnavale Hatchery
8 September 2014EN-EM-EV-DE-1,0772
H304495
Sarah Richards
^../^. I
^11^:,,
Site
Tasmania
Location
Measurement
Water sam Iin
algalBenthicbiomass
Rd Head of HUON Swimming Hole LorkinsOutfall Cam in Ground Brid eisland
in340050 in
downstreamI km u stream u stream Outfall downstream
XXXXX
XXX
Russell
Brid e
The outcomes of the investigation, developed in consultation with the Water Specialist, were:o Confirmation that there are no other inputs into the river between the outfall and the
swimming hole and that the tributaries coming into the river between the outfall and LorkinsRd bridge are very low volume and in good conditioBenthic algal biomass was more than three times higher 400 in downstream 14.9 ing/in') ofthe outfall than at 50 in upstream (4 ing/in'). Fresh green algal growth was only present inthe river from immediately downstream of the outfall. Upstream of the outfall there wassignificant cover of series cent algae, most likely persisting from last summer. The algalcondition description from the Tasmanian River Condition Index is moderate for thedownstream site and low for the upstream site. his change in condition is confirmed to besolely attributed to the influence of the HUON outfall. This changed condition of the river,
Rd
km
from visual appearance, extended to Lorkins Bridge, 3 km downstream and also likelyfurther downstream although the full extent is unknown as river access was limited. Otherinputs to the river may also be present beyond Lorkins Bridgeit is noted that for this level of algal cover and biomass to be present at this time of year isunusual given the short day length, low water temperature and degree of channel shading atthe downstream location (~60%), which are all factors that limit algal growth. In this casethere was also a short accrual period for algal growth to develop since the last flood eventwhich began on 31 July 2014 and remained high for several days.Water quality results are consistent with recent monitoring data provided by HUON. Thesenutrient inputs are sufficient to support the increased algal biomass downstream of theoutfall. All nutrient analytes in the outfall exceed the interim water quality guideline valuesdeveloped for the Russell (H292966) and largely derived from 80" percentile of the inflowmonitoring data conducted by HUON. The outfall levels of ammonia and dissolved reactivePhosphorus exceed the limits proposed by Davies 2009, intended to be applied at 50 indownstream (H3,5209). These limits are still exceeded at double the Davies limits, whichaccounts for the immediate dilution achieved at the outfall location.
This investigation provides strong evidence to support EPN requirements being imposed onHUON to reduce the nutrient inputs Into the Russell River from the fish farm discharge.
imposing those requirements is consistent with objective 6.1 (a) of the State Policy on WaterQuality Management I 997, which states that water quality management will be focused toachieve water quality objectives that will maintain or enhance water quality.
Actions
I. Provide a copy of the sampling results to HUON2. Prepare an EPN requiring reduction in nutrients in the fish farm outfall.
From;
To:
CG
Subject:Data
Dear Mr Swan
Richards. Sarah (Environment)
Geoffrev Swan (aswan@adjv8. netau\
SchaaD. Alex (Environment\; Cook, Darrvl W (Environment\, Dowson. Grea P IEnvironment)Response to your questionsWednesday, 24 September 2014/2:23:45 PM
Please find below my response to Your questions.
I. Can we please view the esults and the eport of Your recent water testing. Mr Schaapearlier advised me these es ts wou d be forwarded to me as soon as they were
completed
A letter has been prepared to provide this information to You and will be sent to You in duecou rse.
2. Did You test for DSSo ved Oxygen, total A ga Count/Screen, any metals or Bent 'cMacroinvertebrates.
Do and benthic chlorophyll-a were measured. Metals and benthic invertebrates were notmeasured as the investigation was focussed on determining algal response to the outfall
discharge. Requirements for benthic invertebrate sampling will be included in the EPN as part ofHuon Aquaculture's routine monitoring required by the EPN. Metal analysis has not beenincluded as the fish farm activity does not pose a risk of metal toxicity.
3. As the "Aut or tv on ate test g" can you p ease 'nstruct me as to what tests should
independently conduct to reassure myse f of the health of our river - with theknowledge that at innimum there 's a 24/7 discharge of fish faeces and undigested fishfood that could conta'n a I man er of compounds - research has revealed that ch cken
manure for exa PIe 's a know 'rigredient n some Aquaculture f'sh food
Please seek independent advice on Your specific health concerns and the aspects of water
quality that could impact this. The monitoring shows that total and dissolved forms of nitrogenand phosphorus are greatly below toxicity trigger values such as those published in the ANZECCwater quality guidelines.
Monitoring conducted by the EPA and Huon Aquaculture includes total and dissolved forms ofnitrogen (ammonia, nitrate, nitrite) and phosphorus, dissolved oxygen, pH, temperature,turbidity, conductivity and benthic Chl-a. This monitoring has been focussed on addressing aeutrophication issue - that is the impact of nutrients on the river ecosystem. There is noinformation to suggest there are other environmental risks.
As the fish are being grown for human consumption the use of harmful concentrations ofsubstances and the presence of pathogensin the feed is strictly controlled. For furtherinformation I advise You to direct this question to Huon Aquaculture or perhaps contact
Skretting - a Tasmanian fish food producer that most of the companies use. I am aware thatpoultry meal is a common ingredient but manure sounds very unlikely. Aquaculture feeds forfinfish will be specifically formulated to meet fish health and growth requirements
4. A e you in a POSi on o adv'se me p ease of t e tota dally vo ume of f'sh faeces, poowater with fine so ds and o ganic mat er that s d s harged f o the flow thro gh
sys em at the HAC Lonnava!e Hatc ery
The volume of water that passes through the farm is around 0.3 cumecs per day. I can't providea direct mass or volume of fish faeces - this information is unknown. Huon have previously
provided their water quality monitoring to You and this information shows the concentrations ofnutrients in the farm discharge. Total and dissolved forms of nitrogen and phosphorus are thechemical components of the farm waste (including faeces and uneaten feed) that areenvironmentally relevant. Huon operate a drum filter on the main stocking area of the farm toremove solids. This is a major portion of the waste generated by the farm and is effective atreducing the nutrient loading in the discharge.
5. Are You able to adv'se me of any such calculation between th's 24/7 discharge and therespective water vo ume n the ussel R ver at var ous months of the Year in order toput me at ease that Your one off test'rig was not 'ust a " ucky" day with respect to
pollution in the r'ver.
The river has a highly seasonal flow pattern with higher flows in winter and spring, and lowerflows in summer and autumn. The average summer flow is 1.5 cumecs and average winter flowis 7.5 cumecs. in rare events (less than 2% of the time) the flow can be as low as 0.3 cumecs.
The monitoring results were consistent with data provided by Huon Aquaculture in theirmonitoring so suggests that conditions were typical on the day we sampled. The discharge limitsthat will be required by the EPN are conservative to address low flow conditions.
6. Mr Schaap adv'sed me the t 81 wate a a ys s d d show a contrast 'n results from
upstream of the discharge to downstream of the d scharge - can you elaborate on thisplease, and can You adv'se where the tests were taken a orig the r ver.
This information will be provided to You by letter. Briefly - the monitoring showed a threefoldincrease in benthic algal biomass below the outfall and no other significant inputs to the riverwere found. The water quality monitoring is consistent with Huon's monitoring. An EPN will beissued to Huon to require a reduction in the nutrient concentration of the discharge.
7. I request once aga'n, can please view the report prepared by Professor Peter Davies in2009 under instruct'on of the EPA. I accept he was being paid by HAC - but I also knowthis was a requirement a'd down by the EPA and FS n order to conform to theconditions of the Hatchery 'cence If this report is so POSit ve about the river and showsno reason for any concern then surely it is n the EPA's riterest to share this with ourcommunity.
This information is the property of Huon Aquaculture and I do not have their consent to provide
it to You.
8. Are You now able to advise with certainty that It s totally acceptable for the public andchildren alike to bath In the Russell River at any point In the river downstream of the
24/7 discharge p'pe from the Hatchery.
The conditions that we observed in the river during the sampling, and as consistent with routine
monitoring provided by Huon Aquaculture, did not reveal any toxic levels of nutrients or levels ofalgae that would pose a risk to health. I do not have information that supports the presence ofrisks to health.
Sarah Richards
BSC(Hons) PhD
Senior Environmental Officer
Industrial OperationsEPA Division
Department of Primary Industries, Parks, Water and EnvironmentGPO Box 1751, Hobart TAS 7001
Ph: 0361654607
Fax: (03) 62333800h iEmail:
Internet: WWW. environment. Ias. gov. aU
CONFIDENTIALITY NOTICE AND DISCLAIMERThe information in this transmission may be confidential and/or protected by legal professional privilege. and is intended only tothe person or persons to whom 11 is addressed. If you are not such a person. you are warned that any disclosure. copying ordissemination of the information is unauthorised. if you have received the transmission in error. please immediately contact thisoffice by telephone. fax or email. to inform us of the error and to enable arrangements to be made for the destruction of thetransmission. or its return at our cost. No liability is accepted for any unauthorised use of the information contained in thistransmission
V V
Assessed by the Department of Primary industries, Parks, Water and Environment under the Right to information Act 2009
Level7. ,34 Macqt, aria SIreel, Huba, ITASGPO Box, 550, Hobarl, TAS 7001 AUSlralia
E, ^dries: Sarah RichardsFax: +6,362333800+6136/654607Ph:
Sarah. Richards@environment. lag. gov. auEmail:^b: unw, .epa. 188.90v. auOur Rel: EN. EM-EV-Dell0772jH309524
3 October 2014
Dear Mr
I am writing to infomi you of the resul!s of a recent invest 19allon of water quality and algal conditionin the Russell River in relation to Ihe discharge Irom Huon Aquaculture's fish farm at Lonnavale.This invesligallon was prmnpled your report of unseasonal algal growlh in the RusseW Rive o18 August 2014. The results of samples and measurements collected on 28 August 20,4 arepresented in Ihe table below.
The water quailly sampling results show values that are consistent with monitoring that is routinelyconducted by Huon Aqu^culture. The nullienls in the oull;all ale present at low calcenlralions Ihaldo not pose toxicity hazards. However, Ihey are likely 10 be sumolen to increase algal biomass.The nulrtent levels are consistenl with Ihe Ihreefold increase in benthlc Chlorophyll-a, a standardmeasure o algal biomass. observed at a point 400m downstream of the ouijall in comparison to asample from 60m upstream of the ouwall. This evidence 18 suggestive or eutrophication of the riverresinllng from the discharge. The investigation did not unCover any other signlftoant nutrient inputsin10 the river Ihal would innuence river condlllon at that downslream location.
RESULTS FROM RUSSELL RIVER SAMPLING
ERMRONME, IrPROTEcrioNAUTHORiiY
^
.
Russell River Sam 11n Results - a So ternber 2014., km
60 unUpstream of UpstreamOutfall
of OutranRussell Rd
120010207.396.8
6.64 7.39122512.85
104.8 102.30,0630,063
5.47.3<0,0060,0090,010<0,002<0.10<0.100,007
Analyte
time Sam ledH
Tern Brature C
Do (inglL and %)
.
Coilducilvil ms/cmTurbidl NTU
Ammonia in in.Mlrale inNitrate and Nilrlle in LNilrlle in ILTo181Nllro an in itTo!al K eldahl Nilro en in ADIBsolved ReacllvePhos horous in AToIal Phos horus in ILBenthlc Ch!oro h 11-a in in
* . No sample cowerled
This is not a
complete copy ofthe original record
Outlall
.
12.66.997.1312.6
104.60,084
120,0320,0120,014<0,0020.120.11
0,017
400 inDownstream
of Quitall
11057.126.8212.93106
0,0636.6
0,0130,0090,011<0,002<0.10<0.100,011
3 kmDownstream
o1 OurrallLorkln6 Rd
14157.1
8.0512.66to6.20.065
6
<0.014
0.01 <0.0114.9
Assessed by the Department of Primary Industries, Parks. Water and Environment under the Right to information Act 2009
As you are aware. there has been a substantial reduction in stocking of the fish farm, together withother environmental management measures, since concerns about the Russell River were firstraised with the EPA some years ago.
NOMithstaridlng the above, lire increased algal biomass detected recently. together willI youranecdotal evidence rom river observations, indicates that Ihe waler quality of the fish farm ouijallis mimendng river condition for a significant distance downstream arxi most likely as far as Loll^sRoad. The extent of this impa61 is not acce able. An Environment Protection Notice whichrequires a staged reduction in nutrients discharged to the Russell River has been issued to HuonAquaculture.
Please contact Saiah Richards as per the details at the head of this correspondence if you haveany enquiries.
Yours sincerely
,^!,,,,,John Mollison
Delegate for the Director, Environment Protection Authority
Level7,134 Macquarie Street, Hobart TASGPO Box 1550 Hobarl TAS 7001 Australia
Enquiries Sarah RichardsFax: +6,362333800+6136/654607Ph
Sarah. Richards@environment. tas. gov auEmail
WWW. epa taS goV auWeb
(EN-EM-EV DE-,, 07721 H318707) sinaOur Ref'
22 October 2014
Mr Geoffrey Swan
Dear Mr Swan
COPY OF ENVIRONMENT PROTECTION NOTICE 7677/1
I refer to your request to receive a copy of the Environment Protection Notice (EPN) No. 7677/1that was issued to the Huon Aquaculture Company Pty Ltd in relation to the fish farm activity atLonnavale. The EPN formalises environmental management requirements for the activity,including the management of water quality of the discharge from the flow through farm to theRussell River. The EPN also requires submission of various management plans primarily relatingto wastewater irrigation and sludge disposal, which are the waste streams from the recirculationfacility at the site.
This office recently conducted an investigation of algae in the Russell River in the vicinity of theflow through farm outfall, the results of which have been previously provided to you. The farmdischarge was found to be causing an increase in algal biomass for several kilometres downstreamof the outfall. This change in algal biomass was not found to constitute serious or materialenvironmental harm, however the extent of the impact is not considered acceptable in the longterm.
ENVIRONMENr PRO^CrioN AUTHORITY
^^
TASMANIA
Huon Aquaculture is required to develop a nutrient reduction plan, to provide detailed ecologicalmonitoring of the Russell River and to comply with water quality limits for the flow through farmdischarge to the Russell River. The EPN requires nutrients in the discharge to be reduced over aperiod of three years to allow implementation of nutrlent reduction measures by Huon Aquaculture.
Please contact Sarah Richards as per the details at the head of this correspondence if you haveany enquiries.
^
Yours sincerely
,:AirDelegate for the Director, Environment Protection Authority
co:
Encl.
jqallichan@huonaquaepm au
Copy of EPN 7677/1
Assessed by the Deparbnent of Primary Industries, Parks, Water and Environment under the Right to Information Act 2009
Level7. ,34 MPCquarie SIree!. Hoba, ITASGPO Box 1650j HDbarl, TAS 7001 AUSl, am
Enquiries: Salah Richards+6/30/654607Ph: Fax: +61362333800
Saran. Richards@environment. lag. gov. auEniall:ab: WWW. opalas. goV. aU
Our Ref; (EN-EM. EV-DE-,, 07721 H304432) stria
26 September 2014
Mr Peter Bender
Managing DirectorHuon Aquaculture company Ply Ltd961 ESPeranbe Coast RoadDOVER TAS 7117
Dear Mr Bender
ENVIRONMENT PROTECTION NOTICE 76771,HUON AQUACULTURE COMPANY, LONNAVALE FISH FARM
Please find attached to Ihis correspondence, Environment Protection Notice (EPN) No. 7677/1,issued to the Huoii Aquaculture Company Ply Ltd in accordance with Section 440)(a) and (0) ofthe Environmental Management and Pof/adon Control Act 1994 (EMPCA). The grounds liponwhich the ^;PN 18 issued are set out in the EPN. The EPN lakes effect on the day on which it isserved.
EruRonMENTPRO^nonAUTHORIT,
in accordance with section 44(3) of Ihe EMPCA, you are required 10 comply willI the conditionscontained in Schedule 2 of this EPN.
TA S M A N IA
I Understand that draft versions of the EPN were discussed with your representatives and thatchanges were made as a result of their comments.
This EPN requires a reduction in nutrients being discharged to the Russell River from the flowthrough fish farm at Lonnavale in order to minimise the impact of tile discharge upon rivercondition. The EPN also formalises other environmental requirements for the above activity,particularly the management of waste streams generated by both the flow through farm and theroclrculalion hatchery and grow oul facllily.
A fee of $3. , 82.00 is payable for 1119 preparation of the enclosed EPN. An invoice is enclosed.Please also be advised that Sec!toll 44(3A) of the EMPCA allows for reasonable costs associatedwith ensuring compliance wilh an EPN 10 be recovered.
You may appeal to the Resource Management and Planning Appeal Tribunal against Ihe EPN, oragainst any requirement contained in the EPN, within fourteen days from the date on which the.EPN is served, by writing 10:
The ChairpersonResource Management and Planning Appeal TribunalGPO Box 2036HOBART TAS 7001
Lodgemenl of an appeal may be subject 10 the payment of a fee. 11 is suggested Ihal you contactthe Titbtinal on (03) 61656794 to ascertain the reqiiiremenls for making an appeal.
Assessed by the Department of Primary Industries,
if you hav ny queries regarding this correspondence, please contacthead of Ih s respondence.
Yours SI re y
Alex aapI ECTOR, E VIRONMENT PROTECTION AUTHORITY
I"
Parks, Water and Environment under the Rightto Information Act 2009
IEnd: EPN 7677/1
invoice
the officer named at the
Geoffrey Swan
Subject:
From: Schaap, Alex (Environment) mailto:Alex. SchaaSent: Monday, 10 November 20144:08 PMTo: Richard Dax
Cc: Gay, Michael (Environment)Subject: RE: Russel River Lonnavale
Dear Mr Dax,
I agree that we have taken far too long to resolve the issues in the Russel River but there are many reasons for that(including that the EPA did not have regulatory jurisdiction over the operations of the hatchery It is not truehowever that the degradation continues uriabated. The water quality of discharges from the hatchery has improveddramatically over that period. What Is evident from recent observations (including Mr Swann's reports) is thatnutrient levels in the river are sometimes still at high enough levels to induce excessive algal growth. This is anunacceptable impact for a river which had otherwise experienced very little issue with algal growth and I haveassured Mr Swann that this will not be allowed to continue. t is per aps worth noting however that otherindicators of river health remain very favourable and there e no public health concerns at current dischargelevels.
FW: Russel River Lonnavale
I have now issued an Environmental Protection Notice upon the hatchery, effectiveIy taking over regulatoryjurisdiction from the Council. That EPN puts the hatchery on a pathway of improving discharge water quality. Thecontaminant limits will be further reviewed in the context of updated environmental impact Information over thecoming months. it may well be the case that further reductions in effluent limits may be necessary and if that is thecase then those limits will be reduced. That decision will then have the evidentiary basis to be sustained againstappea .
environment. tos. ov. au
Finally, I will observe that I and others within the agency have considerable sympathy for Mr Swann and understandhis frustrations but the approach to regulation of this issue will not change from that previously explained unlessnew information warrants it.
Alex Schaap
Director Environment Protect on AMhonty
General Manager - EPA Duns onDepartment of Primary Industries, Parks. \Inater and Environment134 Macquane SI (Lands Building)GPO Box, 550 HDbarl. Tas 7001Ph. (03) 6 654523 Fax (03) 62333800emai alex schaap@envi^, menl Ias gov au
From: Richard Dax tmailto:daxfishl bi ond. coinSent: Monday, 10 November 20142:14 PMTo: Schaap, Alex (Environment)Subject: Russel River Lonnavale
Dear Mr. Schaap,
I refer to recent correspondence between your agency and Geoffrey Swann, a most concerned resident beside theRussel River Lonnavale.
75.6' I, ,
Geoffrey has sought my advice on the matters he raises on the basis that I was responsible for first bringing thedegradation of this mountain river to the attention of the bureaucratic bodies variously responsible in 2006-- yeseight years ago!
it is clear from his research and collation of the significant complaints made to Your Department that little haschanged in seven or eight years and that degradation to this once pristine waterway continues uriabated. I entirelyagree with Geoffrey that it is beyond the bounds of reason that the people of Lonnavale continue to suffer at thehands of a now publicly owned entity Huon Agriculture.
The present situation is blatantly contrary to both the past promises of Huon Aquaculture and actions that shouldhave been taken by your department some years ago and Geoffrey is patently correct in his insistence thatdemonstrative action is taken immediately.
I understand that Your officers find it difficult to either absorb or answer the legitimate questions Geoffrey raisesand that the collateral that he provides is somewhat lengthy. However, I think it should be clearly understood thatGeoffrey is driven not only by passion but by the ongoing inability of your Department to address his complaints orindeed my own all those years ago and as yet not satisfactorily answered .
In essence I believe then that the necessity to fully document the matters in question to the present time is a directresult of the inactions of the EPA and it is this alone that has resulted in such lengthy documentation.
I also believe that the below extract from correspondence sent by you to Geoffrey is reprehensible and unbefittingYour position as a senior public servant, given his genuine concerns and the unmet responsibilities of YourDepa rtment.
it is however a so unhelpful to continue to harangue Sarah with this constant email barrage, pleasejust let her geton with heriob. She w'11 provide you with the information we have but she wi not be directed by you indeterinn'rig our sampling regime or the analyses or calculations we undertakein managing the impact of thishatchery . Please also des'st with perpetuating the notion that she is being un easonab y defensive of the hatcheryoperator, she is not, she is simply trying to present you with a balanced view. Please also be very clear that it makesnot a jot of difference to me how many politicians or lobbyists You circulate these emails to and who is interested, Iwill deal w'th the 'ssues ent'rely on their inert, regardless of who is interested and what lobbying may be occurring.
I shall be further assisting Geoffrey if and when required and hope to see a much improved and sympatheticapproach to him from the EPA. it is an indictment that this issue continues uriabated without serious action toovercome the in equities involved.
Richard C Dax
334 Sugarloaf RdCarlton River Tasmania 7173
E daxfishl@bigoond. coin
M: 0417591289
P: 61362658557
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Level6.134 Macquarie Sireel. HobarlTASGPO Box 1550. Hobart. TAS 7001 AUSlralia
Enquiries'Ph:
FaxEmail:Web:Our Ref
Alex Schaap+6136/654523+61 362333800
Alex Schaap@environment. Ias. gov. au\unv, .epa. Ias. gov. auH3276,6
19 November 2014
Mr Geoffrey Swan
Dear Mr Swan,
I refer to your letter of 8 November regarding concerns about Hatchery discharges to the RusselRiver.
I believe that my previous email correspondence with you deals with the issues raised. I willhowever endeavour to explain in more detail the rationale for the approach being taken.
As previously advised, I agree with you that excessive algal growth in the Russel River isunsatisfactory from both an ecological and an environmental amenity basis. I am also satisfiedthat the nutrient rich discharge from the hatchery is a significant driver for that algal growth. Whilehuge improvement has already been made, I also agree that this situation .should have beenremedied some years ago and I remain committed to appropriate Iy remedying the issue.
The remedy must however be implemented in accordance wilh proper regulatory process. Thecompany would quite rightly object and probably appeal in law if proper process was notfollowed. Of particular importance in that regard is to ensure that there is adequate evidentiarybasis upon which to found regulatory measures and that appropriate opportunity is provided for thecompany to implement whatever further improvement is necessary.
As I have previously indicated, I think that discharge levels for nutrients in the hatchery effluent willprobably need to come down further in order to adequately address the issue but it is reasonablethat such a move would occur with a sound evidentiary basis, have due regard to both theenvironmental risk and the impact of those measures upon the company. in this case I do notbelieve that there is a substantial risk of serious or sustained harm to the river requiring immediateresolution, indeed the ecological health of the river appears to be in very good shape despite theexcessive algal growlh of recent years,
I inspected the river today and while I noted that there was somewhat greater benthic algal growthdownstream of the hatchery, that growlh did not in my view represent evidence of environmentalharm requiring any urgent remedy. As someone with over thirty years of experience on this river, Iwas pleasantly surprised that there was so much less algal cover than we saw prior to thecorrective measures taken by the hatchery operator in recent years'
Having said that, the risks to the longer term ecological health of the river through nutrientenrichment must be addressed and in any event there has clearly been a substantial impact onenvironmental amenity during warmer low flow periods which warrants resolution sooner ratherthan later.
ENVIRONMENT PROTECTION AUTHORITY
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TA S M A N I A
it is my judgement that the EPN recently issued will do this in a reasonable and defensible manner.The initial discharge limits are, as you have observed, not a great immediate imposition on theoperator, They are set at the 80th percentile of recent discharge monitoring data and are intendedto ensure that the discharge is immediately capped and also to ensure that there is a real
compliance standard in place to deal with any episodic discharges which might otherwise be inexcess of the levels observed in previous monitoring data.
The EPN then imposes lower discharge limits at time intervals Intended to give the operator theopportunity to take the necessary action to achieve those limits. Those time intervals arenecessary because the operator will need to take some difficult decisions and perhaps employcostly measures to achieve the lower discharge levels. The EPN also provides that a furtherreview must be undertaken and reported by May next year and the EPN makes clear that furtherreductions in discharge levels may be imposed if the review demonstrates that this is warranted
I do hope that you will gain a better appreciation of the approach we are taking when you sit downwith Darryl and Sarah to work through the details of the rationale behind the ERN and ourregulatory approach. That conversation will also provide you with the opportunity to explore therange of questions you have raised. I am hopeful that the discussion will demonstrate to you whywe think the p ach being taken offers the best prospect for the most timely long term solution.
I do not prop se t correspond with you again until that discussion has taken place.
Yours sincer y
,lei^^To^! EN IRONMENT PROTECTION AUTHORITY
D r Mr Swan
Richards. Sarah IEnvironmentlGPorrra Swan
RE: Fallow up regards Water Qualky in Russell MerFriday, November 21,20144:04:56 PM
Both the flow data and the monitoring data are the property of Huon Aquaculture and I am unable to provide them to you. The farm fiodata of 0.3 cumecs is an average. In times of very low flow in the river the farm would take less water. The flow data was taken from agauge board at Lorkins Bridge that was established and monitored by Huon Aquaculture
The calculation of the EPN data Included monitoring valu s for June and July
I have sent you an meeting Invitation for 3 Decem er to throu h y ur furth r qu
Sarah
From: Geoffrey Swan [mallt0:95wan@adjv8. netau]Sent: Thursday, 20 November 20143:50 PMTOB Richards, Sarah (Environment)Subject: FW: Follow up regards Water Quality in Russell River
Dear Dr Richards I had misplaced this email this 15 in fact what I was followi g up wi my email to your earlier today I do hope you canassist me soon on this please
And Mr Schaap sent me a letter yesterday referring to the EPN showing the 80'' percentile - I have the results of your testing 8''September, and results of HAC testing 2010 - up to 7'' May 2014 are there further test results taken by EPA or HAC since May 2014 thatwere Included in calculating your EPN numbers that I am not aware of? it so I would really appreciate a copy please
Thank you and regards
Geoffrey Swan
From; Geoffrey Swan rinailto:OSwan@activ8. netaulSent: Friday, 14 November 20145:07 PMTo: Sarah RichardsCG Lit Smith ismiliztas@amall. coin); rosaliewoodruff@am all coin; Rebecca Hubbard (marine@et. ora. au alex. schaaD@environment. tas. o0v. auJohn. Whittinoton@dojowe. Ias. o0v. au
Subject: FW: Follow up regards Water Quality in Russell River
Dear Dr Richards
10n
I have earlier copied you in on an email I sent to DPIPWE, and again I have copied you in today in an email I have just sent to Acting DirectorMartin Read
I have not heard from you with respect to some questions I raised - so I have sent this again. I know you are usy owever I am not able tomove forward on this since DpiPWE advise me 11 has nothing to do with them - and I am still preparing for a meeting with Mr Bender and Ineed factual information
I rid my
This is getting to difficult for me to understand given DPIPWE are responsible for Rural and Urban Water and as I earlier pointed outDpiPWE 15 responsible for managing and sustainably developing the Tasmania's fresh water resources. it 15 also responsible for developing
and Implementing policy and legislation to support urban water and sewerage reform' You will appreciate whylam confused?
I. Where have you obtained flow rates of the Russell which have determined what 15 acceptable for HAC to discharge?2. How do you know that HAC discharge 0.3 cumecs 24 million litres per day into the Russell River?3. And how regular do you monitor flow - specifically, do you have data 2008 2014 please? Locals tell me the river flows have
decreased marked Iy over the years and I am interested to put some science behind this rather than rely on anecdotal evidence
Thank you and regards
Geoffrey Swan
From: Geoffrey Swan rinailto. OSwan@activ8. netaulSent: Friday, 14 November 20144:55 PMTo; 'Read, Martin (DpiPWE)'CG 'Richards, Sarah (Environment)'; 'Murrey, 10die (DPIPWE)'; 'Chamberlain, Jeffrey (DPIPWE)'; Farrell, rim (IFS) mm. Farrell@its. tas. any. aualex. schaaD@environment. tas. o00. au; 'John. Whitington@dpipwe. has. gov. au'Subject: RE: Follow up regards Water Quality in Russell River
Dear M Read
I am still in pursuit of more information regarding flow data for the Russell River and I am hoping to gain a better understanding as to how it
Mr Swan's consolidated questions to Darryl Cook regarding the Russell River,Lonnavale dated 24 November 20.4.
I. Given the daily discharge from the HAC fish farm is 26,000 kilolitres which issubstantially more than the I 00 kilolitres as is detailed under Schedule 2.3 (a) inEMPCA 1994 - under this clause why does the EPA therefore not formerly recognizethis as a Level2?
2.1 refer to section 15 of the State Policy on Water Quality Management 1997:
Why is the EPA agreeing to a discharge of 26,000 litres per day, 365 days of the year ofraw untreated effluent into our river?
Response
The intention of the "wastewater treatment works" activity definition was tocapture facilities designed for the treatment of sewage and/or industrial processwastewater. Schedule 2.3(a) has been utilised for this purpose since theintroduction of the Environmental Management and Pollution ControlAct in1994. Inland fish farms have never been captured under Schedule during thatperiod.The term 'Sewage' is defined in Tasmania's Plumbing Regulations to mean"waterborne waste of human origin comprising foeca/ matter, grewater, urineor liquid household waste". The term is also typically taken to refer to materialwhich flows in sewers. The Lonnavale fish farm is not a sewage treatment facilitynor does it emit sewage.Notwithstanding the above, the Environment Protection Authority has e ected toregulate the Lonnavale fish farm as if it were a level2 activity. An EPN has beenIssued to restrict the outputs from the fish farm over time. Furthermore a reviewof the environmental performance of all large scale fish farm activities across thstate is underwa and will include a review of the re ulation of these activities.
This Section of the State Policy on Water Quality Management 7997commences with the words A Regulatory authority must not authorise. .. '. it istherefore dealing with the approval or authorisation of discharges. As far as theEPA is concerned discharge from the Lonnavale fish farm was a pre-existingdischarge at the time the EPA commenced regulation of the facility. Presumablythe commencement of the discharge was authorised in some other manner inthe years prior to EPA's involvement.When the State Pollby on Water Quality Management 7997 came into beingthere were numerous pre-existing discharges in place, for exampleapproximately 90 sewage treatment plants. Unfortunately the costs of recyclingor irrigation of effluent tend to be prohibitive, particularly in wetter areas andareas that have insufficient a ricultural or Iantation land in the vicinit .
As mentioned previously, the EPA was not involved in the commencement of theLonnavale fish farm. Having now become involved in regulation of the fish farm,the EPA must adopt a reasonable approach that is proportionate to the degreeof environmental impact.Following a period of seeking improved environmental outcomes via suchmeasures as reduced stocking of the flow through fish farm and installation oftreatment e ui merit see below , an EPN has been issued to further restrict
Level7,34 Madiuarie Street, HobarlTASGPO Box 1550. Hobart, TAS 7001 Australia
Enquiries' Sarah RichardsPh Fax: +61 36233380o+61 36,654607
Sarah. Richards@environment. Ias. gov. auEmalWeb WWW. epa tas goV. auOur Ref (EN-EM-PE-245231 I H340639) sina
22 December 2014
Mr Geoffrey Swan
Dear Mr Swan
Thank you for attending the meeting on Thursday 11 December 2014 during which my staff explainedthe rationale behind Environment Protection Notice (EPN) No. 7677/1, which was issued to HuonAquaculture Company Pty Ltd on 26 September 20.4.
I understand that you remain dissatisfied with the limits imposed upon the Lonnavale fish farm by theabove EPN and the timeframe over which those limits will become increasingly restrictive upon theoperation of the fish farm.
On the basis of water quality and algal biomass data collected independently by EPA Division officers,and data routinely collected and reported by Huon Aquaculture Company Pty Ltd, I am satisfied that theenvironmental impacts caused by the discharge from the Lonnavale fish farm do not warrant strongeraction at this point in time. Data and observations by EPA Division staff during 2014 Indicate that thegrowth of algae has not reached the high levels observed during previous years, nonetheless, the datado indicate that algal biomass is elevated for some kilometres downstream of the discharge and thatthe fish jam is the in a'or contributor of nutrients to this stretch of the river Should future data on water
quality, algal abundance or invertebrate diversity indicate greater impacts than those described above,this office will take appropriate action.
I am aware that during the above meeting concerns were raised by one attendee of seepage from theriver bank in the vicinity of the fish farm discharge. I understand that Dr Sarah Richards is makingarrangements to investigate the alleged seepage. Residents have also raised allegations ofunauthorised discharges during high flow events. Within reason, I am prepared to allocate officer timeto investigate credible observations of such discharges.
As previously advised, I accept that the BOD limit set in the above EPN is higher than necessary and Iintend to amend the EPN to reduce the BOD limit after I have received sufficient data upon which tobase a decision There is no evidence to suggest that oxygen draw down is a current issue in the river.
I note that the email archive in relation to this matter is extensive to an unprecedented level. Pleaseunderstand that EPA Division staff will not always be able to service this level of email correspondence.I have asked relevant staff to prioritise any credible new allegations of actual serious or materialenvironmental harm
FOLLOW up FROM MEETING RE LONNAVALE FISH FARM
ENVIRONMENT PRO^CnoN AUTHORITY
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TA S M A N I A
^
Yours sincerely
^^^-^John Mallison
Delegate for the Director, Environment Protection Authority
co Mr John Whiting ton Secretary DPIPWE
BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY
Level6. ,34 Macquarie Street, Hobart TASGPO Box 1550, Hobart, TAS 7001 Australia
EnquiriesPh:FaxEmail:Web:Our Ref
MIChael Gay+61 36,654507+6,362333800
Michael Gay@environment Ias gov. auWWW. epa. tas gov auH355649
O 3 AR 2015
Mr Geoffrey Swan
Dear Mr Swan
Thank you for your email congratulating me, and other m of the EPA Board on ourappointment. Thank you also for bringing to the Board's attention, your concerns about theimpacts of the Huon Aquaculture fish farm on the Russell River at Lonnavale.
The Environment Protection Authority comprises the EPA Board and the EPA Director. TheBoard's statutory roles primarily relate to the assessment of environmental impacts fromproposed developments. The Director is responsible for day to day regulation against therequirements of the Environmental Management and Pollution Control Act I994.
I understand the EPA Director issued an Environment Protection Notice to Huon Aquaculturein September 2014. I further understand that since sending the email to me, you haveparticipated in a meeting with Darryl Cook and Dr Sarah Richards from the EPA Division andhave received further written correspondence from the EPA Director, which addresses anumber of your queries about the emission limits set in the EPN. I trust that you now have abetter understanding of those matters.
I have every confidence that the Director will continue to monitor environmental performanceof the fish farm, and ensure compliance with the requirements of the EPN.
Yours s' cerely,
ENVIRONMENT PROTECTION AUTHORITY
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^
arren Jones
ChairpersonBOARD OF THE ENVIRONMENT PROTECTION AUTHORITY
Minister for State GrowthMinister for EnergyMinister for Environment, Parks and HeritageLevel 10 15 Nunay Street HOBART TAS 7000 AustraliaGPO Box 123 HOBART TAS 7001 Australia
Ph: +6136/657739
Email Minister. Groon@dDactas. 90vau
Web WWW stategrowth. Ias. gov. aiJ WWW. do Dwe Ias gov. au WWW skills tas EOV. an vrww. cg. t's gov an
Scott Bacon Nip
353 Main Road
GLENORCHY TAS 70 O
Dear Mr/con ^'6/1'Thank you for your enquiry about the impacts of salmon forming on the Russell and Little Denison Rivers,particularly impacts on recreational fishing, raised by you following representations from constituents.
The Government recognises the value and importance of recreational fishing resources. Both the Russelland Little Denison Rivers have fish farm activities that take water and return water to those rivers after it
has passed through the fish fann. it Is rec ised that the nutrient inputs in the fish form effluent in acause some level of ch ge to bad<810 rid river conditions.
To address environmental concerns about Impacts on these rivers the Director, EPA has issued anEnvironment Protection Notice to Huon Aquaculture for their activity on the Russell River and is inconsultation regarding a soon to be issued notice for Snowy Range Aquaculture on the Little DennisonRiver. The notices require management of the quality of discharged water to manage impacts on rivercondition and to ensure that these activities operate within appropriate environmental performancestandards.
I 8 AUG 2015
I
TasmanianGovernment
.,
in regard to the impacts of these adjvities on recreational fishing resources, the Inland Fisheries Service(IFS) has advised that it has conducted electrofishing surveys in the Russell River downstream of theLonnavale fish farm over the past three summers. The surveys have shown a broad size range in thebrown trout population, ridicating successful natural recruitment. The data also showed a trend ofIncreasing numbers of fish over 220 mm in the population, possibly indicating recovery from heavycoiniorant predation, which was noted in trout fisheries across the state in 20 I I - 12 and 20 12- 13.
Whilst comparative surveys were not undertaken in the Little Dennison River, the IFS has advised that asimilar result would be expected.
it should also be noted that the lower sections of these rivers are subject to variable seasonal recreationalfishing effort, which can also lead to localised depletion of trout over the minimum legal length of 220
Please contact Minister Rockliff' if you require further information about the management ofrecreational fisheries.
^r
^
14 AUG 1115
mm
Should you require further information on the details of regulatory action taken for the fish farm activitieson the Russell and Little Denison Rivers, I would be pleased to facilitate a briefing for you with theDirector, ERA. Please contact my advisor, Mr Simon Willcox on 0458 395 60 I or
ac. tas. ov. au if you wish to pursue this,simon. willco
Yours sincerely
Mathew Groom NIP
Minister for Environment, Parts and Herita^
^,
Geoffre Swan
Subject:
From: Simone Watson tmailto:swatson huonvalle .has. ov. auSent: Friday, December 4,20154:50 PMTo: Geoffrey SwanSubject: RE: Can I hear from You please
Dear Geoffrey
Thank you for fo lowing up in relation to my email to you of 28 October 2015. The Council has undertakeninvestigations including with site nspections and there was no evidence of fa' ing septics from properties in LorkinsRoad.
FW: Can I hear from you please
Kind regards
Simone Watson
General Manager
Phone 03626403191 Fax 0362640399Address 40 Main Street, HuonvilleEmail swatson huonvalle tas ovau I Web WWW. huonvalle .tas. ovau
o3a\;14r^Q ^
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